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

Summary

The Supreme Court of Arkansas affirmed an award of attorneys’ fees and costs to the hospital defendants after the doctor’s claims were dismissed following remand. The court held that the fee motion was timely because it was filed within fourteen days after the circuit court finally resolved the remanded claims, and that the doctor could not relitigate the hospital’s substantial compliance with its bylaws. The court also held that the governing rules did not require a two-stage fee determination or a hearing that the doctor had not requested. No separate opinions were filed.