Patton v St. Francis Hosp.
Ga. Ct. App.

Patton had his privileges revoked by the MEC after a full peer review hearing. He sued for damages and injunctive relief. The hospital was granted summary judgment under HCQIA. Patton appealed and lost. The Court stated there was immunity under both the federal and state laws. The Court used the four prongs of the HCQIA and stated that a death made the act in furtherance of health care, they had a year long peer review which showed a reasonable effort to obtain the facts, the notice and hearing procedures were adequate and that Patton did not show enough evidence to overcome the presumption that the hospital believed its actions were reasonable. This last one is an impossible burden