National Practitioner Data Bank

Chadha v. Charlotte Hungerford Hosp., No. 17029 (Conn. Feb. 15, 2005)

A hospital contacted the impaired physician program of the Connecticut State Medical Society regarding its concerns about a psychiatrist whose practice of medicine was without reasonable skill and safety. Other physicians at the hospital submitted sworn statements to the department of public health expressing concerns about the psychiatrist’s safety. These statements or affidavits were then considered by the board regarding whether the psychiatrist's license to practice medicine should be suspended. Later, the board ordered a summary suspension of the psychiatrist’s license pending a final determination by it. The hospital issued this information to the National Practitioner Data Bank ("NPDB"). Subsequently, the board issued a final decision ordering the immediate suspension of the physician’s license to practice medicine.

The psychiatrist issued a complaint against the hospital accusing the hospital of issuing a false report to the NPDB. He also asserted defenses such as absolute immunity for statements made in connection with quasi-judicial proceedings and qualified immunity under state law. The trial court concluded that the psychiatrist failed to prove malice for qualified immunity. However, it ruled that the hospital also failed to meet its burden. The appellate court affirmed the trial court’s ruling and denied the hospital's summary judgment motion on the ground of absolute immunity.

The Supreme Court of Connecticut affirmed the lower court’s ruling that the proceedings of the board that suspended the psychiatrist's license were quasi-judicial in nature and that a claim of absolute immunity is given to participants in judicial and quasi-judicial proceedings and constitutes a basis for an appealable final judgment.