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

Summary

The Supreme Court of New Jersey reversed the Appellate Division and held that the Hospital’s memorandum was privileged under the Patient Safety Act because the Hospital’s evaluative process complied with the statutory requirements in effect at the time of its creation. The Court emphasized that later regulations were not applicable retroactively and that the privilege does not extend to the dissent’s view, which argued the committee was insufficiently composed.