Res Judicata
Lin v. Hurley Med. Ctr. Bd. of Hosp. Mgrs. (Mich. Ct. App. Sept. 20, 2005)
A hospital denied to extend staff privileges to a urologist
after receiving negative reports of the doctor's past performance. The doctor
filed a lawsuit claiming the hospital failed to offer him an opportunity
to be heard, which effectively denied him procedural due process rights. The
hospital then granted the doctor a hearing and upheld its decision to deny
him membership. The doctor next filed a motion to amend the complaint claiming
the hospital's actions were arbitrary and capricious and violated his substantive
due process rights. The trial court denied the doctor's motion to amend. At
this point, the doctor filed another lawsuit claiming that the hospital's denial
of membership to him was arbitrary and capricious. The Court of Appeals of
Michigan held that the doctor's second complaint was barred by res judicata
because the issue of whether the hospital had acted arbitrarily had been decided
on the merits in an action that was a final decree and which involved the same
parties.