Natarajan v. Dignity Health

Summary

The court held that a hospital peer review hearing officer's prospect of future employment may, depending on the circumstances, constitute a disqualifying direct financial benefit because it can create an intolerable risk of bias. Such employment prospects are not automatically disqualifying; the inquiry is context-specific and considers factors including control over selection and the extent and likelihood of future work. The court affirmed because the hearing officer's three-year bar on reappointment by the hospital and the absence of evidence that the parent organization controlled his selection showed no intolerable risk of bias.