Abrams
Abrams v. St. John's Hospital & Health Center
Opinion
Opinion
Croskey, J.
Plaintiffs Arnold R. Abrams, M.D. (plaintiff or Dr. Abrams) and Arnold R. Abrams, M.D., a professional corporation (professional corporation or medical corporation) appeal from an order denying their request for a preliminary injunction. Plaintiffs sought an injunction prohibiting the defendant St. John’s Hospital and Health Center (hospital) from terminating a contract between the medical corporation and hospital without first complying with certain contract provisions, hospital bylaws and California case law. The trial court denied the injunction because (1) it found plaintiff was not likely to succeed on his contract cause of action and (2) there were adequate remedies at law with respect to his tort causes of action.
In this appeal, we determine that doctors who obtain exclusive contracts to supply medical services to hospitals are bound by the contractual termination provisions to which they have agreed. These doctors are to be contrasted with other staff physicians who do not hold these exclusive contracts but who are entitled to certain due process hearing rights pursuant to hospital and medical staff bylaws.