Treister v. American Academy of Orthopaedic Surgeons
Illinois Appellate Court
78 Ill. App. 3d 746 (1979)
Dr. Treister (plaintiff), already holding hospital staff privileges and board certification without Academy membership, was rejected from the American Academy of Orthopaedic Surgeons (defendant) after being told of unspecified adverse information he was never allowed to see, identify the source of, or respond to; he sued seeking due-process-based procedural rights in the application process, arguing Academy membership was a practical necessity for professional recognition, and the trial court denied the Academy's motion to dismiss.
Whether courts can review the application procedures of a private professional association when membership in the organization is an economic necessity for members of the profession.