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.