Leadbitter v. Keystone Anesthesia Consultants, Ltd.

In this medical negligence action, the Pennsylvania Supreme Court addressed whether certain portions of a hospital’s credentialing file for the doctor who performed a patient’s surgery are protected from discovery. After the plaintiff suffered injuries related to complications from surgery, he claimed that the hospital’s credentialing and privileging process was inadequate and that it knew or should have known the surgeon lacked the expertise to be authorized to perform the surgery. The plaintiff sought the complete credentialing and/or privileging file for the surgeon. The question turned on the Court’s interpretation of Pennsylvania’s Peer Review Protection Act (PRPA), 63 P.S. §§ 425.1-425.4. The Court held that the hospital’s credentials committee qualified as a “review committee” under the PRPA and cannot be compelled to disclose its internal operations.

Leadbitter-1-Majority-Opinion

Leadbitter-2-Concurring-Opinion