Brown v. Duval County Medical Society

31 Fla. Supp. 2d 56
CourtCircuit Court for the Judicial Circuits of Florida
DecidedNovember 14, 1988
DocketCase No. 88-15422-CA
StatusPublished

This text of 31 Fla. Supp. 2d 56 (Brown v. Duval County Medical Society) is published on Counsel Stack Legal Research, covering Circuit Court for the Judicial Circuits of Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brown v. Duval County Medical Society, 31 Fla. Supp. 2d 56 (Fla. Super. Ct. 1988).

Opinion

OPINION OF THE COURT

MAJOR B. HARDING, Circuit Judge.

ORDER GRANTING DEFENDANT’S MOTION TO DISSOLVE TEMPORARY INJUNCTION

This cause came before the Court for hearing on the defendant’s motion to dissolve the temporary injunction previously entered by this Court on October 11, 1988. Having heard the evidence and the arguments of the parties, the Court is of the opinion that the defendant’s motion is well taken, and that the temporary injunction should [57]*57be dissolved. The Court’s opinion and order is based upon the following findings of fact and conclusions of law.

Findings of Fact

On October 3, 1988, the plaintiff Robert C. Brown, Jr., M.D., received a hand delivered letter from the defendant Duval County Medical Society (“DMCS”). [Plaintiff’s Exhibit “1”; Exhibit “A” to Plaintiff’s Motion for Temporary Injunction]. The letter was signed by Jack L. Sapolsky, M.D., as Chairman of the DCMS’s Judicial Committee (“the Committee”). The letter informed Dr. Brown that the Judicial Committee was reviewing his care of a particular patient, and requested his attendance at a meeting scheduled for 5:30 p.m. on October 11, 1988, some eight days later.

On October 10, 1988, counsel for Dr. Brown contacted Dr. Sapolsky by telephone to discuss the situation. Dr. Sapolsky declined to specify for Dr. Brown’s counsel the nature of the complaint against Dr. Brown. Dr. Sapolsky informed counsel that the meeting would be informal, that it would involve the three members of the Committee and two physicians practicing within Dr. Brown’s area of specialty (obstetrics and gynecology), and that the presence of counsel and the presentation of witnesses on Dr. Brown’s behalf would be inappropriate. Dr. Sapolsky explained that the meeting was informal and that its purpose was purely to discuss the case with Dr. Brown as a means of factual investigation.

• On October 11, 1988, Dr. Brown, through his counsel, filed a motion with this Court seeking a temporary injunction preventing the DCMS from conducting any investigation concerning Dr. Brown’s handling of the particular patient at issue. Dr. Brown’s motion was sworn to in accordance with Fla. R. Civ. P. 1.610. Although the motion sought a temporary injunction without notice to the defendant, the Court contacted by telephone William S. Burns, Jr., as counsel for the defendant, to discuss the defendant’s position with respect to the injunction. After the Court heard from defense counsel, the Court determined that based upon the record before it, the injunction should issue.

On November 2, 1988, the DCMS filed a motion to dissolve the temporary injunction, together with an affidavit signed by Dr. Sapolsky in support of the defendant’s motion. At defense counsel’s request, the court scheduled a hearing on the Motion to Dissolve for November 8, 1988, within the five days prescribed by Fla. R. Civ. P. 1.610(d).

At the hearing on the motion to dissolve, the court heard testimony [58]*58from Dr. Sapolsky as to the procedures employed by the DCMS Judicial Committee in cases such as that involving Dr. Brown, as well as the specific handling of Dr. Brown’s case. As explained by Dr. Sapolsky, the DCMS is a component local organization of the Florida Medical Association (“FMA”). When the FMA receives a complaint against a physician, its normal practice is to refer the complaint to the local medical society within the physician’s geographical area for initial investigation. When the DCMS receives such a referral from the FMA, as it did in this case, the referral is routed to the DCMS’s Judicial Committee, a three-member body composed of each of the three immediate past presidents of the DCMS. The Committee examines the complaint and determines whether, using the expertise and specialization of the Committee members, it can address the complaint without outside consultation. In this case, that was not advisable, since Dr. Sapolsky is a urologist and the other two members of the Committee— Dr. Charles Hayes and Dr. Will Dawkins — practice internal medicine. Thus, in accordance with normal Committee procedures, Dr. Sapolsky transmitted the complaint to two other physicians chosen by Dr. Sapolsky, each of whom specializes in obstetrics and gynecology, for their review. Dr. Sapolsky testified that he deliberately chose the Committee’s two consulting physicians in this case so that neither would have had substantial contact or practice with Dr. Brown.

Following the initial review of the complaint letter by the Committee members and the two consultants, Dr. Brown received his invitation to the meeting to be held on October 11, 1988. Dr. Sapolsky testified that this was the normal practice of the Judicial Committee in cases such as Dr. Brown’s. In accordance with normal Committee procedures, Dr. Brown was told the name of the patient involved, but was not given a copy of the complaint letter in advance of the meeting.

As Dr. Sapolsky testified, the Committee does not provide the physician with an advance copy of the complaint letter due to concerns over confidentiality. Dr. Sapolsky also explained, however, that once the physician attends the informal conference, at which he does receive a copy of the complaint, the physician is allowed any reasonable number of follow up conferences with the Committee and the consultants in order to explain all facts and circumstances relevant to the particular case.

As a general rule, the only persons in attendance at the informal conference would be the members of the Committee, its consultants, and the physician involved. However, Dr. Sapolsky also testified that if a physician were to request that his counsel or another doctor within his specialty area be allowed to be present at the Committee meeting, [59]*59simply to observe the process, Dr. Sapolsky as Committee Chairman would probably allow that, within the exercise of his discretion and on a case by case basis.

Following the informal conference (or series of conferences, as the case may be), the Committee forms an opinion as to what further handling the case should receive. The Committee’s consensus is then reported back to the DCMS’s referral source, which would be the FMA in a case such as Dr. Brown’s.

If the Committee concludes that there appears to be no cause for further investigation, it so reports to the FMA. If on the other hand the Committee concludes that reasonable grounds exist for an investigation into whether the physician has violated state law or state regulations, that is reported to the FMA as well. In such a case, the FMA would then refer the matter on to the Florida Department of Professional Regulation (“DPR”) for its investigation and review. In matters referred for DPR investigation, the DCMS takes no further action pending resolution of any investigation the DPR sees fit to undertake.

Finally, if the Committee concludes that no grounds exist to believe that state law is implicated, but that the case may present a potential violation of the DCMS’s own by-laws, the matter is then handled in accordance with the DCMS’s own internal procedures set forth in Section 108.0 of its by-laws. Under those procedures, the physician receives written notice of the charges, an opportunity for a more formal hearing before the Committee, a review of the Committee’s recommendation by the DCMS’s Board of Directors and, at the physician’s option, a review by the full membership of the DCMS as well.

There was no evidence presented to indicate any personal bias or malice toward Dr.

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Bluebook (online)
31 Fla. Supp. 2d 56, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brown-v-duval-county-medical-society-flacirct-1988.