Energy Group Inc. v. Liddington

Plaintiff-appellant William Dorn III, an orthopedic surgeon, brought an action for defamation against two hospitals and their administrators arising from the disclosure of evaluative information contained in plaintiffs personnel file. In this appeal from a summary judgment adverse to plaintiff, we consider the nature and extent of statutory privileges applicable to a hospitals communications regarding peer evaluations of a doctors performance there, where such communications were made (1) to the Board of Medical Quality Assurance (BMQA) and (2) to another hospital which requested such information in order to aid in its consideration of whether to grant the doctor staff privileges.