Robert C. Villare, M.D.

Summary

The Supreme Court of Delaware affirmed summary judgment for Beebe Medical Center on two independent grounds. Assuming the medical-staff policy was enforceable, Villare was required to follow its internal review procedures before pursuing litigation, and his failure to do so barred relief. In addition, Villare could not recover damages because he failed to substantiate their amount with substantial evidence rather than speculation, despite ample opportunity to do so.