Mateo-Woodburn v. Fresno Community Hospital
Court of Appeal of California, Fifth District
270 Cal.Rptr. 894 (1990)
Fresno Community Hospital's (FCH) (defendant) anesthesiology department operated as an "open staff" of independently competing physicians, which led to communication problems, scheduling delays, and patient-safety concerns; the Board of Trustees decided to close the department and instead contract exclusively with Dr. William Hass to provide all anesthesia services through individual contracts with anesthesiologists, giving Hass authority to select physicians and set their hours. Seven of thirteen existing anesthesiologists signed with Hass, five refused, and a sixth wasn't offered the chance but later testified he wouldn't have signed anyway; those five physicians, including Mateo-Woodburn (plaintiffs), sued FCH, alleging their staff privileges were unlawfully terminated, modified, or curtailed. The trial court ruled for FCH, and the physicians appealed.
Whether a hospital's policy decision to make administrative changes affecting physicians' medical staff privileges will be disturbed if the decision is not substantially irrational or otherwise illegally discriminatory.