A patient alleging negligence by a hospital requested a letter during the discovery process to be used as evidence in her case. The letter was from a physician to the Chairperson of the Hospital's Department of Obstetrics and Gynecology. It contained factual information regarding the care of the patient bringing the suit and the events surrounding the episode in question. The hospital refused to produce the letter, arguing that it was protected information under the Illinois Medical Studies Act, and contending that the letter was protected as a part of the hospital's quality improvement process.

The appeals court disagreed, and held that the letter was not a part of the peer review process, nor a part of the quality improvement committee's work. The court held that the statute is designed to protect the confidentiality of information shared in the quality improvement process, and is limited to that arena. This letter was merely information between hospital staff, rather than information initiated, created or generated by a peer review committee. The court determined that the committee would have had to have been involved in the process for protection to attach. Accordingly, the hospital was required to provide the document to the plaintiff.