Potvin v. Metropolitan Life Insurance Company
California Supreme Court
997 P.2d 1153 (2000)
MetLife (defendant) terminated Dr. Potvin's (plaintiff) status as a preferred provider without cause under a contract allowing either side to end the arrangement on 30 days' notice, later explaining the termination was due to his malpractice history (four prior suits, three dismissed, one settled); after MetLife denied his request for a hearing, Potvin sued claiming the termination devastated his practice and reputation. The trial court granted MetLife summary judgment, the court of appeals reversed finding Potvin was owed a hearing, and MetLife sought further review.
Whether an insurer with power substantial enough to significantly impair an ordinary, competent physician's ability to practice medicine in a geographic region must comply with the common-law right to fair procedure before removing that physician from a preferred-provider list.