Schmitt v. Meritcare Health Sys. (Summary)

DEFAMATION

Schmitt v. Meritcare Health Sys., No. 20130013 (N.D. July 22, 2013)

The Supreme Court of North Dakota affirmed a lower court’s grant of summary judgment in favor of a hospital, holding that the physician’s allegations that the hospital’s responses to a credentialing questionnaire were defamatory failed to state a claim. The court found that the hospital could not be held liable for the statements it made in the questionnaire, which the physician admitted were “technically true,” and did not fit within any of the defamatory meanings under state law. The court also rejected the physician’s claim that the hospital and an unrelated clinic conspired to prevent him from obtaining privileges at other hospitals.