Villare v. Beebe Med. Ctr. (Summary)

MEDICAL STAFF BYLAWS

Villare v. Beebe Med. Ctr., No.: 08C-10-198 JRJ (Del. Super. Ct. Mar. 19, 2014)

The Superior Court of Delaware ruled that medical staff bylaws do not create an enforceable contract.  The court reasoned that the bylaws expressly state that “‘[a]ppointment to the Medical Staff is a privilege and not a right’ and otherwise set forth the process to acquire Medical Staff privileges. In other words, the Bylaws provisions at issue are not written to provide a basis for breach of contract, but to set forth a procedural process.”  Accordingly, the court granted the hospital’s motion for summary judgment against a surgeon’s breach of contract claim.