Bonni

FACTS AND PROCEDURAL HISTORY

A. Factual Background We start with our Supreme Court’s recitation of the facts set forth in Bonni v. St. Joseph Health System (2021) 11 Cal.5th 995 (Bonni). “Aram Bonni, M.D., is a surgeon specializing in obstetrics and gynecology who began practicing in 1998. He received staff privileges at defendant Mission Hospital Regional Medical Center (Mission) in 2002 and at an affiliated hospital, defendant St. Joseph Hospital of Orange (St. Joseph), in 2010. Bonni would face peer review proceedings at both hospitals, which would ultimately lead to a settlement with St. Joseph’s [(the St. Joseph settlement)] wherein Bonni agreed to resign and to a decision terminating Bonni’s staff privileges at Mission. “The proceedings at St. Joseph’s began not long after Bonni received staff privileges in 2010. That same year, Bonni performed a surgery proctored and assisted by the hospital’s chief of obstetrics and gynecology, one of the named defendants. Like several of Bonni’s surgeries, the surgery involved use of a robotic assistant to supply three-dimensional imaging and cut and cauterize tissue. On this occasion, the robot’s camera provided only two-dimensional…