Eugene Garrow, M.D., Plaintiff-Respondent v. Elizabeth General Hospital and Dispensary, Defendant-Appellant

Summary

The Supreme Court of New Jersey affirmed the trial court's dismissal, holding that the hospital's internal procedures must be exhausted before judicial review, that a physician is entitled to limited pre‑hearing discovery of material underlying the Board's decision, and that counsel may be present at the hearing subject to reasonable regulation. Justice Pashman concurred in part and dissented in part, arguing that exhaustion should not apply where fundamental fairness is at issue.