Victor Bernard Williams, M.D. v. Baptist Health D/B/A Baptist Health Medical Center

Summary

The court held that Williams's medical-staff-bylaws claim was subject to limited judicial review, was equitable in nature, and therefore did not require a jury trial; it also affirmed the finding that Baptist Health substantially complied with its bylaws. The court further held that Williams was entitled to discovery under the peer-review privilege exception and that denying the discovery was not harmless as to his racial-discrimination and tortious-interference claims, requiring reversal and remand of summary judgment on those claims. Summary judgment was otherwise affirmed on the remaining challenged claims, and the intermediate appellate court's opinion was vacated.