Katz v. Hospital Auth. of Rabun County

Dr. Daniel Katz appeals from the trial court’s grant of summary judgment on his claim that the Hospital Authority of Rabun County Hospital improperly revoked his emergency room privileges. The trial court found that the unrebutted evidence in the record was that although Katz’s emergency room staffing contract had been terminated, his professional privileges were not revoked. Although the trial court’s finding was a correct statement of fact, it did not support the grant of summary judgment. Accordingly, for the following reasons, we reverse.

The facts in this case, viewed in the light most favorable to Katz, as nonmovant, are as follows. The Hospital hired Dr. Katz to work in its emergency room on July 6, 1998. A year later, Dr. Kathy Easterling, the Hospital’s chief of staff, called a meeting to discuss Katz’s performance as an emergency room physician. As a result of this meeting, Easterling sent Katz a letter stating that “We, therefore, under Medical Staff Bylaws 5.3-3 c are revoking your emergency room staff privileges as of this date.” The letter went on to inform Katz that he had a right to request a hearing to appeal this action. The chairman of the hospital authority also sent Katz a letter on that same date, stating that in light of the revocation of his emergency room privileges, his contract with the hospital to perform services as an emergency room doctor was terminated.