Guier v. Teton County Hospital District
2011 Wyo. LEXIS 32
| Wyo. | 2011Background
- St. John’s Medical Center issued a six‑month reappointment to Guier in 2006 under a Medical Staff Reappointment Agreement restricting conduct.
- The Agreement prohibited shouting, discourteous conduct, public criticism, threats, and other unprofessional behavior by Guier.
- A focused performance review in 2005–2006 found ongoing behavioral issues affecting staff relations.
- In October 2006, staff petitioned the MEC to address disruptive conduct; the MEC suspended Guier for 29 days and ordered an investigation.
- An ad hoc committee and the hospital CEO investigated six incidents of alleged misconduct from July to October 2006.
- The MEC recommended termination of Guier’s medical staff privileges; Guier requested a contested case hearing, which was held before a Judicial Review Committee (JRC).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the burden of proof at the contested case hearing complied with governing rules. | Guier argues WAPA requires clear and convincing proof. | Hospital bylaws set a preponderance standard and govern the burden. | Burden of proof under bylaws applied; not clearly erroneous. |
| Whether Guier received due process in the hearing process. | Notice and process were insufficient due to gaps in informal handling. | Guier had notice, counsel, witness cross‑examination, and an impartial tribunal. | Due process satisfied under the record; no reversible error. |
| Whether the Board’s decision was supported by substantial evidence. | Record lacks detailed, corroborated evidence for six incidents. | Six witnesses and documented reports provide substantial evidence of misconduct. | Yes; substantial evidence supports termination. |
| Whether the Board’s decision was arbitrary or capricious. | Noncompliance with informal Disruptive Practitioner Policy rendered process arbitrary. | MEC followed its bylaws; policy is permissive and does not replace Bylaws. | Not arbitrary or capricious under the circumstances. |
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 standard)
- Pratt v. Board of Trustees of Memorial Hospital, 262 P.2d 682 (Wyo.1953) (hospital bylaws must be reasonable; court defers to hospital management)
- Painter v. Abels, 998 P.2d 931 (Wyo.2000) (clear and convincing standard may apply to licensure disciplinary actions)
- Willadsen v. Christopulos, 731 P.2d 1181 (Wyo.1987) (administrative adjudications default to preponderance unless statute or policy says otherwise)
- Reynolds v. West Park Hospital District, 231 P.3d 1275 (Wyo.2010) (agency decisions reviewed under traditional WAPA standards)