C.A., a Minor, by Her Mother and Guardian Ad Litem, Esther Applegrad, Esther Applegrad

Summary

The Supreme Court of New Jersey held that the hospital memorandum (DV2) was protected by the absolute privilege in the Patient Safety Act because the hospital’s self‑critical analysis complied with the statutory requirements in effect at the time, and therefore reversed the Appellate Division and remanded for further proceedings. Justice Cuff dissented, arguing the hospital’s process did not meet the Act’s requirements and the privilege should not apply.