Sokol v. Akron General Medical Center
United States Court of Appeals for the Sixth Circuit
173 F.3d 1026 (1999)
After Akron General's (defendant) Medical Council grew concerned about surgeon Sokol's (plaintiff) unusually high mortality rate for coronary bypass surgery, an investigatory committee found he had inadequately screened high-risk patients and failed to take sufficient precautions against heart attacks during the procedure, leading the Council to restrict his privileges; although a later hospital hearing committee recommended reinstating his full privileges, the Council rejected that recommendation and an appellate hospital committee affirmed the Council's decision. A federal magistrate judge found Sokol received insufficient notice and that the Council's decision was arbitrary, granting him injunctive relief, and Akron appealed.
Whether a private hospital must provide procedural due process in adopting reasonable, nondiscriminatory criteria for medical staff selection or termination decisions.