PEER REVIEW PRIVILEGE

Logan v. Everett, No. M2005-00012-C.A.-R3-CV (Tenn. Ct. App. Jan. 27, 2006)

A hospital withdrew its recruitment offer after receiving negative references from medical staff leaders and the hospital CEO at the recruit's former hospital. The recruit sued the former hospital and medical staff leaders for intentional interference with a business relationship, alleging that they made false and malicious statements about him. To support his claim, he pointed to telephone verification forms on which medical staff leaders and hospital managers at the recruiting hospital wrote notes about their conversations with the recruit's former hospital and physician colleagues. The Court of Appeals of Tennessee affirmed the lower court's summary judgment in favor of the recruit's former colleagues and hospital, ruling that the telephone verification forms were inadmissible and the defendants were immune from liability under the Tennessee Peer Review Law