Lee v. Hosp. Auth. (Summary)

MEDICAL STAFF BYLAWS – DATA BANK REPORTING

Lee v. Hosp. Auth., No. 04-12353 Non-Argument Calender D.C. Docket No. 02-00073-CV-HL-6 (11th Cir. Jan. 27, 2005)

A physician’s renewal application at a hospital led to the Medical Executive Committee appointing an ad hoc committee to initially investigate misstatements on his application and, later, his competency. The physician resigned prior to the completion of the investigation, and the hospital submitted a report to the National Practitioner Data Bank (NPDB). The physician filed a lawsuit for damages and injunctive relief based on the hospital failing to follow its bylaws and the submission of the NPDB report. Summary judgment was granted by the district court. The United States Court of Appeals for the Eleventh Circuit, in affirming the district court, held that the hospital had followed its bylaws, and that there was no evidence that the hospital made a false report to the NPDB.