Dorn

— Plaintiff-appellant William Dorn III, an orthopedic surgeon, brought an action for defamation against two hospitals and their administrators arising from the disclosure of evaluative information contained in plaintiff’s personnel file. In this appeal from a summary judgment adverse to plaintiff, we consider the nature and extent of statutory privileges applicable to a hospital’s communications regarding peer evaluations of a doctor’s performance there, where such communications were made (1) to the Board of Medical Quality Assurance (BMQÁ) and (2) to another hospital which requested such information in order to aid in its consideration of whether to grant the doctor staff privileges.

Factual Background

In the summer of 1976, plaintiff submitted separate applications for staff privileges as an orthopedic surgeon at Broadway Hospital (Broadway) and Vallejo General Hospital (Vallejo General), both of which were located in the City of Vallejo. Plaintiff was subsequently permitted to perform surgery while being “proctored” at both hospitals. Proctoring is a method by which experienced practitioners at a hospital monitor the progress and evaluate the skills and knowledge of…