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eBook details

• Title: Harston v. Campbell County Mem. Hosp.
• Author : Supreme Court of the United States
• Release Date : January 02, 1996
• Genre: Law,Books,Professional & Technical,
• Pages : * pages
• Size : 66 KB

Description

The essential issue in this case addresses the scope of discovery of hospital information, documents, or other records in an action against a hospital for independent negligence in credentialing and reviewing the staff privileges of a physician, as well as the responsibility of the hospital for patient injuries. The district court limited Carma Christensen Harstons (Harston) efforts to obtain discovery with respect to incident reports relating to her care and materials relating to the appointment, reappointment, credentialing, and privileges of her treating physician. The district court then granted a summary judgment in favor of Campbell County Memorial Hospital (CCMH) after ruling that Harston, in both her individual and representative capacities, had failed to meet her burden to demonstrate any genuine issue of material fact in response to a motion for summary judgment. In resolving these issues, we revisit Greenwood v. Wierdsma, 741 P.2d 1079 (Wyo. 1987), and hold that the trial court erred in limiting discovery. We cannot know how the information sought by the discovery would have benefited Harston in countering the motion for summary judgment but, since Harston never had the opportunity to utilize information that should have been made available, the Order Granting Summary Judgment for Campbell County Memorial Hospital must be reversed. The case is remanded for further proceedings in accordance with this opinion.

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