Buchheit v. Lakeland Health Sys — July 2016 (Summary)

DUE PROCESS AND ANTITRUST

Buchheit v. Lakeland Health Sys.
No. 1:15-CV-1315 (W.D. Mich. July 21, 2016)

The United States District Court for the Western District of Michigan granted a health system’s motion for summary judgment on a physician’s claims asserting violations of due process and the Sherman Antitrust Act.

The health system imposed a precautionary suspension after a quality review raised concerns about the physician’s cases.  Ultimately, the medical staff medical executive committee (“MEC”) decided to permanently suspend the physician. Following a medical staff hearing, the hearing committee voted to uphold the MEC’s decision, which was, subsequently, affirmed by the Board of Trustees.  The physician sued, claiming that his due process rights under the Federal Constitution were violated.  To support his due process claim, the physician argued that the health system failed to follow its own bylaws during the proceedings, he was not allowed to have an attorney present at the MEC meetings, and the decision-makers were biased. The court rejected these arguments and concluded that the physician had a meaningful opportunity to be heard at numerous points in the process, he had an attorney present at the hearing, and there was no evidence that the hearing committee was biased.  The court also cited Sixth Circuit precedent, noting that “compliance with organizational bylaws is not a mandatory requirement of due process.” With respect to the physician’s antitrust claims, the court instructed that the claim repeated allegations underlying the due process claim and the physician failed to offer any allegation of an agreement that affected interstate commerce.  Accordingly, the court granted summary judgment to the health system and declined to exercise supplemental jurisdiction over the physician’s state law claims.