Moore v. Gunnison Valley Hosp.

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In Moore v. Gunnison Valley Hosp., 310 F.3d 1315 (10th Cir. 2002), the Court of Appeals for the Tenth Circuit held that participants in peer review at a hospital were not entitled to the same absolute quasi-judicial immunity as enjoyed by participants in a medical board action against a physician.

The Court observed that "[t]here are no significant procedural safeguards" in peer review at a hospital. Moreover, there is a lack of "direct oversight by a government agency as well as a right to appeal to that agency." Instead, "there is very minimal and undefined oversight by the state medical board and no explicit right of appeal to that board."

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