St. John’s Hospital Medical Staff v. St. John Regional Medical Center, Inc.
South Dakota Supreme Court
245 N.W.2d 472 (1976)
- Written by Angela Patrick, JD
Facts
St. John Regional Medical Center, Inc. (the hospital) (defendant) was a nonprofit corporation that ran a hospital. St. John’s Hospital Medical Staff (the medical staff) (plaintiff) was an unincorporated association of the hospital’s medical staff. When the hospital was formed, it passed a set of medical bylaws governing any medical providers at the hospital, including the medical staff. Under the terms of the medical bylaws, any medical-bylaw amendment needed to be approved by the medical staff before being enacted by the hospital. Later, the hospital wanted to amend the bylaws to make it easier to suspend a member of the medical staff and to require hospital approval of all medical-staff officers. The medical staff would not approve these proposed amendments. The hospital’s board of directors then adopted a new set of medical bylaws without the medical staff’s approval. The hospital claimed that as the corporation, it needed to have full bylaw-amendment powers to help control potential corporate-malpractice liability. The medical staff sued to overturn the hospital’s new medical bylaws.
Rule of Law
Issue
Holding and Reasoning (Miller, J.)
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