Baxter County Newspapers, Inc. v. Medical Staff of Baxter General Hospital

Frank Holt, Justice.

This case arises under the Freedom of Information Act, Ark. Stat. Ann. § 12-2801 et seq. (Repl. 1979). Appellant’s reporter was denied admittance to a meeting of the Credentials Committee of the Medical Staff of the Baxter County General Hospital. The Committee had convened to make an initial determination as to whether the staff privileges of a doctor should be continued. Appellant filed an action in circuit court to declare the Credentials Committee meeting in violation of the FOI. Subsequently, appellant also filed an injunctive proceeding in chancery court to prevent the Medical Staff from holding a scheduled meeting to consider the Credentials Committee’s recommendations on the matter.

Under its bylaws, the Board of Governors of the hospital delegates to the Medical Staff, separately organized with its own bylaws, the authority to evaluate the professional competence of the Medical Staff members for purpose of admission or continuation of the privilege of practicing at the hospital. The staff’s Credentials Committee reviews the information and makes a recommendation to the full Medical Staff, which then votes on the matter; and if unfavorable, an evidentiary hearing is held. The Board then acts on the matter on the basis of the Staff’s recommendation and the hearing transcript. Appellant contends below and here, contrary to the trial court’s findings, that the meeting of the Credentials Committee and the anticipated meeting of the full Staff are subject to the Freedom of Information Act and must be open to the public.

Section 12-2805 of the FOI provides:

Except as otherwise specifically provided by law, all meetings, formal or informal, special or regular, of the governing bodies of all . . . counties . . . and all boards, bureaus, commissions, or organizations of the State of Arkansas, except grand juries, supported wholly or in part by public funds, shall be public meetings.

There is no dispute that the hospital is a county owned facility supported by public funds. Ark. Stat. Ann. § 17-1501 (Repl. 1980). We have held that when a Board is subject to the provisions of the act, its committees are also subject to the act. Ark. Gazette Co. v. Pickens, 258 Ark. 69, 522 S.W. 2d 350 (1975). Unless the questioned meetings here come under the “except as otherwise specifically provided by law” language of the act, the meetings of the Credentials Committee and of the Medical Staff, which are in issue, must be open meetings.

The trial judge consolidated the circuit court action and the chancery petition for injunction. He found the meetings were exempted from the FOI, relying on Act 445 of 1977, Ark. Stat. Ann. §§ 28-934 and 28-935 (Repl. 1979) and Ark. Stat. Ann. § 19-4724 (Repl. 1980). We do not find those statutes create a specific exception to the FOI as is required. Section 28-934 provides that “[t]he proceedings, minutes, records or reports” of such medical review committees “shall not be subject to discovery or admissible in any legal proceeding and shall be absolutely privileged communications; nor shall testimony as to events occurring during the activities of such committees be admissible.” The substance of this section, therefore, deals with the admissibility of evidence or testimonial privilege. Section 28-935 allows disclosure of such data in certain limited circumstances not pertinent here. Section 19-4724 makes it an obligation of any person engaged in work in a licensed hospital, who has information or knowledge relating to the care provided there, to advise review committees of such matters when requested. In Laman v. McCord, 245 Ark. 401, 32 S.W. 2d 753 (1968), we stated the rule that “statutes enacted for the public benefit are interpreted most favorably to the public,” pointing out also that the FOI Act states “except as otherwise specifically [our italics] provided by law, all meetings . . . shall be public meetings.” We there held that a statute providing a “testimonial disqualification” did not suffice as a specific exception. Further it is well established that the FOI Act is to be liberally construed to achieve its purpose. Laman v. McCord, supra; N. Cen. Assn. of Colleges v. Troutt Bros., 261 Ark. 378, 548 S.W. 2d 825 (1977); and Ark. Gazette Co. v. Southern State College, et al, 273 Ark. 248, 620 S.W. 2d 258 (1981).

Appellees contend that if those statutes do not create an exception, the meetings fall under the exception in § 12-2804 for executive session to consider employment, appointment, promotion, demotion, disciplining or resignation of any public officer or employee and the corresponding provision of the County Government Code, Ark. Stat. Ann. § 17-3108 (Repl. 1980). We cannot agree. The doctor here is not a public officer nor an employee of the hospital. His status is that of an individual who has certain privileges extended to him by the county hospital, which is public owned, operated, and supported by public funds.

We hold the FOI Act requires here that the hearing of testimony and a vote on the matter must be in public session and to that extent the finding of the trial court is modified. However, in the circumstances, we think that a discussion or consideration of a resolution of the issue by the committee members may be conducted in executive session. See Ark. State Police Comm’n v. Davidson, 253 Ark. 1090, 490 S.W. 2d 788 (1973); Yandell v. Havana Bd. of Education, 266 Ark. 434, 585 S.W. 2d 927 (1979).

Affirmed as modified.

Purtle and Hays, JJ. concur in part and dissent in part.