Adventist Healthcare v. Behram, 322 A.3d 1

Dr. Steven S. Behram, an obstetrician, had his clinical privileges suspended twice by Adventist Healthcare, Inc. (the Hospital). The second suspension exceeded 30 days, triggering statutory reporting duties.
The Hospital and Dr. Behram entered into a Settlement Agreement, resolving disputes regarding the suspensions. Key terms included the Hospital’s reinstatement of Dr. Behram’s privileges, his subsequent resignation, and the Hospital’s obligation to report the incident to regulatory authorities using specific, agreed-upon language.
The Hospital’s report to the National Practitioner Data Bank (NPDB) included additional, code-generated language that Behram alleged was inconsistent with the parties' agreed terms and defamatory.
Behram filed suit alleging breach of the Settlement Agreement (for the added language in the report) and breach of Medical Staff Bylaws (for not being granted a timely hearing).
The trial court granted summary judgment to the Hospital on both counts. The Appellate Court reversed on the contract claim (reporting to NPDB) but affirmed on the bylaws claim (timely hearing).
The Supreme Court affirmed the Appellate Court’s decision, holding that whether the Hospital’s code selection in its reporting breached the settlement remains a triable issue for a jury, but the bylaws claim was released in the Settlement Agreement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Hospital breached the Settlement Agreement by adding inconsistent language to the NPDB report.	Behram argued the Hospital agreed to specific reporting language and that using additional, code-generated text contradicted the agreement.	The Hospital argued the Agreement did not restrict its selection of reporting codes and required only the agreed narrative text.	The court held a reasonable person would interpret the Agreement to preclude conflicting, code-generated language; the issue of breach is for the jury.
Whether Behram’s claim for failure to provide a timely fair hearing was released in the Settlement Agreement.	Behram asserted he should still be able to bring his claim for lack of timely hearing despite the release language.	The Hospital argued the broad release covered all claims related to the suspension, including the hearing claim.	The court held Behram released this claim in the Settlement Agreement.

Credible Behav. Health, Inc. v. Johnson, 466 Md. 380 (Md. 2019) (objective theory of contract interpretation; written language controls unless ambiguous)
Tapestry, Inc. v. Factory Mut. Ins. Co., 482 Md. 223 (Md. 2022) (plain language and context control contract interpretation)
Spacesaver Sys., Inc. v. Adam, 440 Md. 1 (Md. 2014) (determination of contract ambiguity is a question of law)
Impac Mortg. Holdings, Inc. v. Timm, 474 Md. 495 (Md. 2021) (summary judgment standard and materiality of fact)