Mahan v. Avera St. Luke’s case brief summary
621 N.W.2d 150 (2001)
CASE FACTS
Appellees, a corporation and its individual physicians, filed suit against appellant hospital seeking a writ of mandamus and a permanent injunction for appellant's decision to close its staff with respect to physicians requesting privileges for certain procedures. The trial court granted summary judgment and the injunction to appellees, determining that appellant had breached its staff bylaws by closing the staff without first consulting its staff.
DISCUSSION
CONCLUSION
Judgment reversed. Appellant's decision to close its medical staff was a permissible decision under its corporate bylaws and was done in good faith to insure the continued viability of the hospital; therefore, there was no breach of contract with its medical staff. The medical staff had no authority over any corporate decisions unless specifically granted that power in the corporate bylaws or under statute.
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621 N.W.2d 150 (2001)
CASE SYNOPSIS
Appellant hospital
challenged the judgment of the Circuit Court of the Fifth Judicial
Circuit, Brown County (South Dakota), which granted the appellees'
motion for summary judgment and entered a mandatory permanent
injunction against appellant, in appellees' suit alleging a breach of
appellant's medical/dental staff bylaws in its decision to close the
staff at the hospital.CASE FACTS
Appellees, a corporation and its individual physicians, filed suit against appellant hospital seeking a writ of mandamus and a permanent injunction for appellant's decision to close its staff with respect to physicians requesting privileges for certain procedures. The trial court granted summary judgment and the injunction to appellees, determining that appellant had breached its staff bylaws by closing the staff without first consulting its staff.
DISCUSSION
- The court reversed.
- When appellant made its decision to close the medical staff, it was acting within its powers under its corporate bylaws.
- The decision was a reasonable administrative decision to ensure the continued viability of the hospital.
- Because the actions by appellant were permissible under the corporate bylaws and done in good faith, there was no breach of contract between the appellant and its staff.
- The medical staff had no authority over any corporate decisions unless specifically granted that power in the corporate bylaws or under statute.
- The result reached by the trial court gave the staff an unreasonable amount of authority that was violative of S.D. Codified Laws § 47-23-13 and S.D. Admin. R. 44:04:04:02.01.
CONCLUSION
Judgment reversed. Appellant's decision to close its medical staff was a permissible decision under its corporate bylaws and was done in good faith to insure the continued viability of the hospital; therefore, there was no breach of contract with its medical staff. The medical staff had no authority over any corporate decisions unless specifically granted that power in the corporate bylaws or under statute.
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