Brandner v. Providence Health & Services - Washington

Summary

The court held that Providence violated Dr. Brandner's due process rights by terminating his hospital privileges without prior notice and an opportunity to be heard, because no emergency or demonstrated threat to patient care justified immediate action. It affirmed the determination that Providence's reporting policy was not impermissibly vague or applied arbitrarily, so reinstatement and damages arising from the post-termination proceedings were unavailable. The court also held that Providence did not qualify for federal peer-review damages immunity for the pre-termination violation because later hearings could not satisfy the statutory requirement that fair procedures precede the professional review action.