Covenant Health, Inc. v. The Maine Human Rights Commission

CourtSuperior Court of Maine
DecidedAugust 13, 2021
DocketKENcv-20-23
StatusUnpublished

This text of Covenant Health, Inc. v. The Maine Human Rights Commission (Covenant Health, Inc. v. The Maine Human Rights Commission) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Covenant Health, Inc. v. The Maine Human Rights Commission, (Me. Super. Ct. 2021).

Opinion

ST A TE OF MAINE SUPERIOR COURT KENNEBEC, ss. CIVIL ACTION DOCKET NO. CV-20-23

COVENANT HEALTH, INC., COVENANT HEALTH SYSTEMS, ST. MARY'S REGIONAL MEDICAL CENTER, ST. MARY'S HEALTH SYSTEM, DR. CHRISTOPHER BOWE, DR. DEREK MITTLEIDER, DR. MED KELLEY and CINDY M. BROUSSEAU, DECISION AND ORDER Plaintiffs,

V.

THE MAINE HUMAN RIGHTS COMMISSION, Defendant

Before the Court is Plaintiff Covenant Health Inc. et al. 's Motion for Summary Judgment. This action is related to an underlying Complaint of Discrimination filed with the Maine Human Rights Commission ("MHRC" or "Commission") brought by a physician ("Dr. Jane Doe"). Dr. Doe was the subject of a professional competence committee review and alleges that Plaintiffs unlawfully discriminated and/or retaliated against her.

In response to the Complaint and certain discovery requests made by the Commission, Plaintiffs seek a declaratory order confirming that Plaintiffs are immunized from civil liability under the Maine Health Security Act ("MHSA"), 24 M.R.S. §§ 2501, et seq. and that records relating to the competence committee review are privileged and confidential according to Section 2510-A of the MHSA 1 and 32 M.R.S. § 3296. In opposition to the Motion, the Commission argues that the case should not be decided in favor of Plaintiffs. Rather, the Commission maintains that judgment should be entered in its' favor instead. The parties have waived oral argument.

LEGAL STANDARD

Summary judgment is appropriate if, based on the parties' statements 'of material fact and the cited record, there is no genuine issue of material fact and the moving pai1y is entitled to a judgment as a matter oflaw. M.R. Civ. P. 56(c); Levine v. R.B.K. Caly Corp., 2001 ME 77, ,r 4, 770 A.2d 653. It follows that to survive a moving party's motion for summary judgment, the non-moving pai1y must establish a prima facie case for each of their claims and set forth specific facts showing there is a genuine issue of material fact. Key Trust Co. of Maine v. Nasson College, 1997 ME 145, ,r 10, 697 A.2d 408; see also M.R. Civ. P. 56(e). A fact is material if it has the potential to affect the outcome of the suit. Id. To be considered "genuine," there must be sufficient evidence offered to raise a factual contest requiring a fact finder to choose between competing versions of the truth. Rainey v. Langden, 2010 ME 56, if 23, 998 A.2d 342; Burdzel v. Sobus, 2000 ME 84, if 6, 750 A.2d 573. Fu11her, this showing "requires more than effusive rhetoric and optimistic surmise." Hennessy v. City of Melrose, 194 F.3d 237, 251 (1st Cir. 1999). The Court must ignore "conclusory allegations, improbable inferences, and unsupported speculation." Carroll v. Xerox Corp., 294 F.3d 231, 237 (1st Cir. 2002).

Cross motions for summary judgment "neither alter the basic Rule 56 standard, nor warrant the grant of summary judgment per se." F.R. Carroll, Inc. v. TD Bank, N.A., 2010 ME 115, ,r 8, 8 A.3d 646 ( quoting Wightman v. Springfi'eld Terminal Ry. Co., 100 F.3d 228, 230 (1st Cir. 1996)). "Summary judgment, when appropriate, may be rendered against the moving pai1y." M.R.Civ.P. 56(c).

2 FACTS

The pa1iies have stipulated to the following facts. In April 2019, Dr. Doe filed a Complaint of Discrimination against Plaintiffs alleging discrimination and/or retaliation based on age, national origin, ancestry, race, physical/mental disability, and whistleblower status. (Stip. S.M.F. ,r 10.) The Complaint stated that Dr. Doe is a medical doctor employed at a hospital operated by Plaintiffs St. Mary's Regional Medical Center and St. Mary's Health System (collectively "St. Mary's").

According to Dr. Doe's Complaint, Drs. Bowe, Mittleider, and Kelley were medical doctors who paiiicipated in St. Mary's Medical Executive Committee. (Stip. S.M.F. ir,r 2-4.) The Committee conducted a formal investigation and review of Dr. Doe's practice of medicine and her fitness to practice. (Stip. S.M.F. ,r,r 2-4, 8.) As a result of the review, the Committee issued recommendations, conclusions, and evaluations of Dr. Doe's conduct and imposed certain conditions. (Stip. S.M.F. ,r 9.) Dr. Doe alleges that the actions taken by Plaintiffs because of the review constitute unlawful discrimination and/or retaliation in violation of the Maine Human Rights Act (MHRA) and the Maine Whistleblower Protection Act. (Stip. S.M.F. ,r 11.)

In response to Dr. Doe's Complaint, the Commission initiated an investigation and has sought information and records from Plaintiffs relating to the Committee's investigation, review, and recommendations. (Stip. S.M.F. ,r 13.) Plaintiffs then brought this action and filed their Motion for Summary Judgment, asserting that the Maine Health Security Act immunizes them from all civil liability, including being subject to an administrative proceeding initiated by the Commission. Further, Plaintiffs contend that the documents and information relating to Plaintiffs'

3 professional competence review of Dr. Doe are privileged and protected from disclosure by Section 2510-A of the MHSA and 32 M.R.S. § 3296.

DISCUSSION

I. Immunity from Civil Liability Under the Maine Health Security Act (24 M.R.S. § 2511)

Plaintiffs contend that 24 M.R.S. § 2511 grants them absolute immunity and prevents the Commission from continuing its investigation into Dr. Doe's professional competence review. The court analyzes Plaintiffs' argument in two parts: first, are the Plaintiffs immune from civil liability relating to their participation in the review? And second, if Plaintiffs are immune from civil liability, how does their immunity impact the Commission's investigation?

A. Are Plaintiffs immune from civil liability relating to their participation in Dr. Doe's professional competence review?

Plaintiffs' motion asks the court to declare them immune from civil liability and investigation under Section 2511 of the MHSA. Section 2511 provides:

Any person acting without malice, any physician, podiatrist, healthcare provider, health care entity or professional society, any member of a professional competence committee or professional review committee, any board or appropriate authority and any entity required to report under this chapter are immune from civil liability: 1. Reporting. For making any report or other information available to any board, appropriate authority, professional competence committee or professional review committee pursuant to law. 2. Assisting in preparation. For assisting in the origination, investigation or preparation of the report or information described in subsection 1; or 3. Assisting in duties. For assisting the board, authority or committee in can-ying out any of its duties or functions provided by law.

4 Thus, to determine whether the civil liability provided in Section 2511 applies to Plaintiffs, the Court must determine whether: 1) Plaintiffs work in an occupation or role delineated by Section 2511, and 2) Plaintiffs' actions fall under one of the acts described by Section 2511. If both questions are answered affirmatively, then Plaintiffs are covered by the MHSA's immunity provision.

Dr. Doe's Complaint of Discrimination alleges facts that demonstrate each Plaintiff is an eligible individual or entity under Section 2511. Specifically, 24 M.R.S. § 2502(3) defines a "physician" as "any natural person authorized by law to practice medicine, osteopathic medicine or veterinary medicine within this State." Based on Dr.

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Related

Hennessy v. City of Melrose
194 F.3d 237 (First Circuit, 1999)
Carroll v. Xerox Corp.
294 F.3d 231 (First Circuit, 2002)
Quoddy Realty Corp. v. City of Eastport
1998 ME 14 (Supreme Judicial Court of Maine, 1998)
Burdzel v. Sobus
2000 ME 84 (Supreme Judicial Court of Maine, 2000)
Tomer v. Maine Human Rights Commission
2008 ME 190 (Supreme Judicial Court of Maine, 2008)
Key Trust Co. of Maine v. Nasson College
1997 ME 145 (Supreme Judicial Court of Maine, 1997)
Levine v. R.B.K. Caly Corp.
2001 ME 77 (Supreme Judicial Court of Maine, 2001)
Butler v. Killoran
1998 ME 147 (Supreme Judicial Court of Maine, 1998)
F.R. Carroll, Inc. v. TD Bank, N.A.
2010 ME 115 (Supreme Judicial Court of Maine, 2010)
Rainey v. Langen
2010 ME 56 (Supreme Judicial Court of Maine, 2010)
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Virmani v. Novant Health Inc.
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Bluebook (online)
Covenant Health, Inc. v. The Maine Human Rights Commission, Counsel Stack Legal Research, https://law.counselstack.com/opinion/covenant-health-inc-v-the-maine-human-rights-commission-mesuperct-2021.