Bryan v. James E. Holmes Regional Medical Center

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In Bryan v. James E. Holmes Regional Medical Center, 33 F.3d 1318, 1335, 6393 (11th Cir. 1994), the U.S. Court of Appeals for the Eleventh Circuit held that hospitals and physicians conducting a peer review of another physician enjoy statutory immunity under HCQIA if their action "would promote quality health care," restrain "competent" behavior, and "protect" patients.

The Court reversed an award by a jury in excess of $4 million, by applying HCQIA immunity. The Court stated:

The role of federal courts on review of [peer review] actions is not to substitute our judgment for that of the hospital's governing board or to reweigh the evidence regarding the ... termination of medical staff privileges."

and

"[T]the intent of [the HCQIA] was not to disturb, but to reinforce, the preexisting reluctance of courts to substitute their judgment on the merits for that of health care professionals and of the governing bodies of hospitals in an area within their expertise."

Bryan v. James E. Holmes Regional Med Ctr., 33 F.3d 1318, 1337 (11th Cir. 1994) (internal quotation omitted).

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