Michael D. Brandner, M.d., Appellant v. Timothy Bateman, M.d., Ronald Christensen, M.d., Steven L. Floerchinger…

Summary

The Alaska Supreme Court affirmed summary judgment dismissing Dr. Brandner’s claims against the individual doctors because the record presented no genuine dispute that they satisfied the statutory conditions for review-organization immunity. The court held that the doctors made reasonable efforts to ascertain the relevant facts, reasonably believed termination of Brandner’s privileges was warranted under the reporting policy, and were not motivated by malice. The court also clarified that the superior court applied an incorrect summary-judgment formulation, but concluded that the correct inquiry still required affirmance.