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 plaintiff must exhaust the hospital's internal procedures before seeking judicial review, that the board may delegate the hearing to a committee, that pre‑hearing discovery is limited to material underlying the Board's decision, and that counsel is not constitutionally required at the hearing. Justice Pashman, dissenting in part, argued that exhaustion should not apply here.