A California appeals court ruled Sept. 2 that Stallion Springs Medical Services, a medical staffing company, did not owe a common law duty of fair procedure to an emergency physician it removed from the schedule at Adventist Health Medical Center Tehachapi.
In an opinion published Sept. 22 on law firm Proskauer’s website, the 5th District Court of Appeal granted Stallion Springs’ writ petition. It ordered the Kern County Superior Court to enter summary judgment for the company on all claims brought by Kuljit Hundal, MD.
Dr. Hundal worked in the hospital’s emergency department as an independent contractor through Stallion Springs. In March 2019, a patient posted on social media that he yelled at her and told her to leave. The hospital told Stallion Springs to take Dr. Hundal off the schedule while it investigated, and the company later ended his contract.
Dr. Hundal sued the hospital, its medical staff and Stallion Springs in January 2021. The hospital and medical staff settled and were dismissed in July 2024.
The panel held that fair procedure obligations apply only to quasi-public organizations with enough power to seriously limit a physician’s ability to practice in a region. Stallion Springs staffed only one hospital, did not control medical staff privileges and did not stop Dr. Hundal from practicing elsewhere.
The court wrote that “a staffing company is not like the private organizations to which the common law right of fair procedure has been applied.” It also found that California’s peer review statute puts hearing obligations on a hospital’s medical staff, not on staffing contractors.
Stallion Springs has since dissolved.
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