Anton v. San Antonio Community Hospital

19 Cal. 3d 802, 140 Cal. Rptr. 442, 567 P.2d 1162 (1977)

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Anton v. San Antonio Community Hospital

California Supreme Court
19 Cal. 3d 802, 140 Cal. Rptr. 442, 567 P.2d 1162 (1977)

Facts

Achilles P. Anton (plaintiff), a licensed physician and surgeon, lost his hospital privileges at San Antonio Community Hospital (defendant), a private, nonprofit hospital corporation, after the hospital commenced an investigation of Anton’s hospital medical practices that entailed numerous administrative hearings and judicial review. The trial court sustained the decision of the Judicial Review Committee that had upheld the decision of the hospital’s executive and credentials committees of the medical staff. The trial court’s decision was rendered after the trial court determined that Anton was not entitled to a trial de novo and instead was only afforded judicial review of the administrative record. Anton appealed and argued that the trial court applied the wrong standard of review and that it should have applied the independent-judgment standard of review and allowed Anton a trial de novo.

Rule of Law

Issue

Holding and Reasoning (Sullivan, J.)

Dissent (Clark, J.)

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