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Nanavati v. Burdette Tomlin Memorial Hospital

New Jersey Supreme Court
526 A.2d 697 (1987)


Facts

Dr. Robert Sorensen was an internist who was also the chief cardiologist, chairman of the department of medicine, and a member of the board of governors at Burdette Tomlin Memorial Hospital (Burdette) (defendant). At one point, Sorensen was the primary doctor responsible for reading electrocardiograms (EKGs) at Burdette. Sorensen earned approximately $75,000 annually just from reading these EKGs. Then Dr. Suketu Nanavati (plaintiff) joined Burdette. Nanavati was a board-certified cardiologist. Nanavati and Sorensen got into a dispute about who should get to read EKGs at Burdette. The dispute escalated in various ways. Although it was undisputed that Nanavati did not do anything that harmed patient care in any way, there were allegations that he was disruptive and uncooperative with other staff members in violation of a Burdette bylaw requiring all staff members to work in harmony. Burdette formed several committees to review the allegations and eventually revoked Nanavati’s privileges to work at Burdette. Nanavati sued Burdette, arguing it had not followed its own bylaws before revoking his privileges. The court agreed and ordered Burdette to follow its bylaws. Burdette engaged in more review and then confirmed its revocation of Nanavati’s privileges. Nanavati sued again. Applying different standards of review, the trial and appellate courts both ruled that Burdette’s findings did not justify revoking Nanavati’s hospital privileges. Burdette appealed to the New Jersey Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Pollock, J.)

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