Yedidag v. Roswell Clinic Corp.

Summary

The New Mexico Supreme Court affirmed the Court of Appeals, holding that the Review Organization Immunity Act (ROIA) creates a private cause of action for breaches of its confidentiality provision, that ROIA implies a promise that physician‑reviewers will not suffer adverse employment consequences for participating in peer review, and that the evidence was sufficient for a jury to award punitive damages because Eastern acted wantonly. The Court’s decision rests on a de novo review of the statutory issues and an application of the substantial‑evidence standard to the punitive‑damages award.