From Casetext: Smarter Legal Research

Baldwin County Hospital Authority v. Wright

Court of Appeals of Georgia
Nov 14, 1991
413 S.E.2d 484 (Ga. Ct. App. 1991)

Opinion

A91A0999.

DECIDED NOVEMBER 14, 1991. RECONSIDERATION DENIED NOVEMBER 21, 1991.

Discovery. Baldwin Superior Court. Before Judge Parrott.

Long, Weinberg, Ansley Wheeler, Joseph W. Watkins, Mark E. Robinson, for appellants. Cedric T. Leslie, for appellee.


We granted the application of the Baldwin County Hospital Authority for interlocutory review of the trial court's order allowing discovery from it in a lawsuit filed by a physician denied hospital privileges.

Dr. Wright sued for defamation and also alleged that the Hospital proceedings violated due process based in part on hearsay information.

Since this was an action by a physician denied privileges by a peer review committee contending that false information motivated by malice was the basis of the denial, the trial court concluded that a violation of the peer review statute had been alleged and the privilege did not apply.

This court's analysis reflected in our opinion in Emory Univ. v. Houston, 185 Ga. App. 289 ( 364 S.E.2d 70) (1987) recognized differences in the medical review statute, OCGA § 31-7-140 et seq. and the peer review statute, OCGA § 31-7-130 et seq. As to the privilege from discovery, however, the Supreme Court has held that both proceedings are absolutely privileged. Emory Clinic v. Houston, 258 Ga. 434, 435 ( 369 S.E.2d 913) (1988).

Therefore, the order granting discovery was in error.

Judgment reversed. Sognier, C. J., and McMurray, P. J., concur.

DECIDED NOVEMBER 14, 1991 — RECONSIDERATION DENIED NOVEMBER 21, 1991 — CERT. APPLIED FOR.


Summaries of

Baldwin County Hospital Authority v. Wright

Court of Appeals of Georgia
Nov 14, 1991
413 S.E.2d 484 (Ga. Ct. App. 1991)
Case details for

Baldwin County Hospital Authority v. Wright

Case Details

Full title:BALDWIN COUNTY HOSPITAL AUTHORITY et al. v. WRIGHT

Court:Court of Appeals of Georgia

Date published: Nov 14, 1991

Citations

413 S.E.2d 484 (Ga. Ct. App. 1991)
413 S.E.2d 484

Citing Cases

Patton v. St. Francis Hospital

See Emory Clinic, supra; Eubanks, supra. See alsoFreeman v. Piedmont Hosp., 264 Ga. 343 ( 444 S.E.2d 796)…

Patton v. St. Francis Hosp

The Georgia peer review and medical review statutes, which establish the privilege for "the proceedings and…