Lloyd v. Lawnwood Medical Center

Lloyd v. Lawnwood Medical Center,
No. 99-CA-001180BC (Fla. Cir. Ct. Feb. 16, 2000)

The Board of the defendant
hospital passed an emergency resolution summarily removing all elected Medical
Executive Committee members, department chairs, and committee chairs from their
positions. The Board then appointed new officers. The resolution was a response
to a citation issued by the Agency for Health Care Administration notifying
the hospital that its peer review process was deficient. The Board claimed that
the removal of the officers was necessary to respond to the citation “crisis.”
The court granted the injunction reinstating the elected officers. The court
held that the factual record did not support the hospital’s claim that it was
responding to a crisis and therefore it had no legal justification for removing
the officers in violation of the medical staff bylaws. The court cited the fact
that the hospital had received a satisfactory Joint Commission review the previous
summer. It found that the medical staff’s lack of responsiveness was a long-standing
problem rather than a sudden crisis, which did not justify a violation of the
bylaws.