Guier v. Teton County Hosp. Dist.
2011 WY 31
| Wyo. | 2011Background
- Dr. Guier appeals district court decision affirming St. John's Medical Center Board of Trustees' revocation of his medical staff privileges.
- Issues arose from contested case hearing where the MEC sought to terminate privileges after a Work Refusal Petition and multiple incident reports of disruptive conduct.
- Guier challenged the burden of proof under WAPA versus the Bylaws, and alleged due process deficiencies and concealment of complaints.
- Hospital bylaws allowed a preponderance standard with the MEC first bearing some evidence; the physician bears the burden to persuade that the action should be rejected or modified.
- The court held hospital privileges are not medical licenses; bylaws govern privileging decisions, which must be supported by substantial evidence and follow due process; ultimately the Board’s decision was affirmed.
- Contested case hearing and subsequent appellate review analyzed substantial evidence, burden shifting, and the hospital’s discretion under Wyoming statutes.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Burden of proof in contested case hearing | Guier argues WAPA requires clear and convincing proof | Hospital argues bylaws set a preponderance standard and are within discretion | Burden assigned by bylaws is not unreasonable; preponderance standard upheld |
| Due process in the contested case | Guier claims procedural flaws violated due process | Record shows notice, impartial tribunal, representation, and opportunity to present evidence | Due process satisfied; no reversible error in process |
| Arbitrary or capricious conduct | MEC failed to follow notices and policies; decision arbitrary | MEC properly followed bylaws; policy documents do not replace bylaw authority | Not arbitrary or capricious; within statutory and contractual framework |
| Substantial evidence supporting termination | Insufficient or uncorroborated incidents impeach findings | Six witnesses and documentary records demonstrate unprofessional conduct | Supported by substantial evidence; JRC and Board findings affirmed |
| Relation of staff privileges to medical license | Privileges act as a license-like entitlement affecting career | Privileges are hospital-specific; not a state medical license; standards differ | Privileges are hospital-by-hospital decisions; no conversion to medical license |
Key Cases Cited
- Garrison v. Board of Trustees of Memorial Hospital, 795 P.2d 190 (Wyo. 1990) (great deference to hospital decisions; rational basis and substantial evidence required)
- Pratt v. Board of Trustees of Memorial Hospital of Sheridan County, 262 P.2d 682 (Wyo. 1953) (hospitals may prescribe rules; decisions must be rational, not arbitrary or discriminatory)
- Willadsen v. Christopulos, 731 P.2d 1181 (Wyo. 1987) (standard adjudicatory hearing burden of proof under agency practices)
- Painter v. Abels, 998 P.2d 931 (Wyo. 2000) (preponderance generally used for licensing-related discipline; notice substantial rights)
- Dale v. S & S Builders, LLC, 188 P.3d 554 (Wyo. 2008) (substantial evidence standard for agency findings)
- Dorr v. Wyoming Bd. of Cert. Pub. Accountants, 146 P.3d 943 (Wyo. 2006) (clear and convincing standard not universal for all licensure matters)
- Devous v. Wyoming State Bd. of Med. Examiners, 845 P.2d 408 (Wyo. 1993) (license discipline standards and WAPA applicability)