Sokol v. Akron General Medical Center case brief

Sokol v. Akron General Medical Center case brief summary
173 F.3d 1026 (1999)

CASE SYNOPSIS

Defendant appealed from the judgment of the United States District Court for the Northern District of Ohio finding that defendant hospital arbitrarily limited plaintiff's hospital privileges.

CASE FACTS
Plaintiff cardiac surgeon brought an action against defendants in order to prevent defendant hospital from placing restrictions on his hospital privileges. Defendants claimed that plaintiff's patients had an excessively high mortality rate due to poor case selection, and that an excessive number of patient deaths may have been due to insufficient myocardial protection. The trial court granted plaintiff's request for a permanent injunction. Defendant hospital filed an interlocutory notice of appeal.

ISSUE
The issue on appeal was whether plaintiff had sufficient notice of the charges against him to adequately present a defense before the hospital hearing committee.

DISCUSSION

• The court reversed the trial court and determined that plaintiff had sufficient notice. 
• Plaintiff knew that the medical council's decision was based upon the results of studies, knew the identity of his patients, and had access to the autopsy reports. 
• Defendant hospital also notified plaintiff of the grounds for the medical council's decision. 
• The court held that it was well within defendant hospital's broad discretion to limit plaintiff's hospital privileges.

CONCLUSION
The court reversed the judgment of the trial court and held that the trial court abused its discretion in ruling that defendant hospital arbitrarily limited plaintiff's hospital privileges. Plaintiff was provided sufficient notice of the charges against him in order to present a defense before the hospital hearing committee. The court held that it was within defendant hospital's broad discretion to limit plaintiff's hospital privileges.

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