Ardisana v. N.W. Cmty. Hosp., Inc.,
No. 1-02-2700 (Ill. App. June 23, 2003)

A hospital was held in contempt for refusing to produce certain documents from hospital quality committees requested in discovery by a malpractice plaintiff. The hospital claimed the documents, as part of the peer review process, were privileged under the Medical Studies Act. The lower court ruled that the documents were equivalent to “results” of the peer review process, which were not privileged under the Act. The appellate court overruled the lower court, holding that, although “results” are discoverable, the documents at issue were not the “results,” but the recommendations and internal conclusions of the peer review committee and therefore not discoverable. The appellate court also vacated the contempt order.