Sadler v. Dimensions Health Corporation,
No. 1625, Sept. Term, 2000 (Md. Ct. Spec. App. December 28, 2001)

An OB/GYN whose clinical privileges were terminated based on quality of care concerns sued the hospital, the hospital president, the president of the medical staff, the vice president of medical affairs, three OB/GYNS and the physicians from Johns Hopkins who had been retained to review her practice. She alleged breach of contract and sought a declaratory judgment that her privileges at the hospital had been illegally terminated. She claimed that the MEC had no authority to impose proctoring and monitoring requirements and that the imposition of those requirements was not reportable to the National Practitioner Data Bank.

The trial court granted summary judgment in favor of all defendants, ruling that "the actions taken in compliance with the bylaws of the medical staff were supported by substantial (although disputed) evidence."

Agreeing that there was substantial evidence to support the termination, the Court of Special Appeals of Maryland affirmed the lower court ruling. It also held that the MEC did have the authority to impose monitoring and proctoring requirements and that, because they lasted more than 30 days, they were reportable to the Data Bank.