Moore v. Gunnison Valley Hosp.

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."