Sood v. Univ. of Iowa (Summary)

ADMINISTRATIVE REMEDY

Sood v. Univ. of Iowa, No. 13 – 0870 (Iowa Ct. App. Mar. 26, 2014)

The Iowa Court of Appeals affirmed a lower court’s grant of summary judgment in favor of a defendant university hospital and its board of regents and against the plaintiff, a former physician employee, on the physician’s breach of contract claim.

The physician filed a lawsuit against the hospital and its board for breach of contract, among other things, alleging that the hospital failed to follow its rules and regulations in revoking the physician’s clinical privileges and reducing his compensation.  The lower court granted summary judgment in favor of the hospital and the board and the physician appealed.

The appeals court found that the hospital and the board were state administrative agencies that had (1) established their own grievance and appellate policies; and (2) adopted specific rules in relation to the appointment and termination of physicians, the qualifications necessary to obtain staff membership and the grant, modification or termination of clinical privileges.

The court found that since the physician’s breach of contract claim stemmed from (1) the hospital’s opinion of his job performance; and (2) the hospital’s alleged failure to follow its own procedures when it revoked his clinical privileges, the physician’s claim necessarily implicated the hospital’s administrative procedures and thus was not actionable in state court unless the physician exhausted those procedures.