Villare v. Beebe Med. Ctr., Inc. (Summary)

REAPPOINTMENT/CREDENTIALING

Villare v. Beebe Med. Ctr., Inc., No. 08C-10-189 JRJ (Del. Super. Ct. May 21, 2013)

The Superior Court of Delaware granted in part and denied in part a hospital’s motion to dismiss, after a physician brought suit for failure to renew his privileges (the “Credentialing Claim”). The physician had previously sued the hospital for wrongful termination of his trauma services contract, but that suit was unsuccessful (the “Contract Case”).  The hospital argued that the doctrines of res judicata barred his Credentialing Claim, which was based on alleged procedural breaches in the reappointment process three years after the physician’s trauma contract was terminated for cause, because it came from the same causes of action and facts as the Contract Case.

The superior court held that the physician’s Credentialing Claim should not be barred, as each of his suits was based on two separate events that occurred roughly three years apart, and therefore were two separate causes of action. However, because the damages pertaining to the Contract Case were fully adjudicated in the earlier litigations, the superior court found that the physician would be collaterally estopped from alleging that the termination of his trauma services contract led to his failure to be reappointed or from seeking related damages.