Hernandez v. Overlook Hospital

POLLOCK, J.,

dissenting.

The majority acknowledges that in a proceeding to terminate a medical resident from a residency for academic reasons a private hospital must provide the resident with a fair procedure. Ante at 81-82, 692 A.2d at 977. According to the majority, the resident’s right to a fair hearing includes the right to representation by a union representative, a peer, another physician, or a professor. Ante at 76-82, 692 A.2d at 974-977. Contrary to the rulings of the lower courts, however, the majority denies the resident the right to representation by counsel. I respectfully dissent.

In my opinion, it is fundamentally unfair to deny a medical resident the right to counsel at a proceeding to terminate his or her residency. Consistent with that conclusion, the Chancery Division held “that a resident terminated from a private hospital’s residency program has the right to have counsel attend and introduce evidence at a hospital hearing concerning the resident’s termination.” 291 N.J.Super. 462, 473, 677 A.2d 811 (1995). The Chancery Division further held that Dr. Hernandez had the right at her expense for a court reporter to record the hearing. Id. at 477, 677 A.2d 811. The Appellate Division affirmed both holdings. 293 N.J.Super. 260, 680 A.2d 765 (1996).

*83In denying Dr. Hernandez the right to counsel, the majority emphasizes that Overlook Hospital’s decision to terminate her residency involves only academic freedom. The majority also emphasizes that the presence of a lawyer would unduly complicate the conduct of the hearing. I disagree with both characterizations.

Admittedly, a residency is a critical part of a doctor’s training. A residency, however, differs significantly from the education that a medical student receives in medical school. In the first two years of medical school, students generally attend lectures as they would in other graduate schools. During the last two years, the training is more clinical. Following graduation, the ensuing residency is often described as “post-graduate training.” Dr. Hernandez was a medical school graduate to whom The New Jersey State Board of Medical Examiners had issued a residency training permit.

As critical as a residency is to the training of a doctor, it is not solely an academic exercise. Residents also care for patients. Often they are the doctors present in the hospital during evening hours, on weekends, and on holidays. In many hospitals, they respond to patient emergencies such as cardiac arrest, arrhythmia, and bleeding. On patients’ charts, residents sometimes change medication, make adjustments in intervenous fluids, and enter other orders affecting patient care. Although these entries are subject to review by an attending physician, the review often occurs after the fact.

The majority points out that as a resident Dr. Hernandez “could not admit or discharge patients, and could not prescribe drugs for out-patients without the signature of a licensed physician.” Ante at 71, 692 A.2d at 972. Missing from that description is any acknowledgment of the acts that Dr. Hernandez could perform. According to the Board of Medical Examiner’s letter that accompanied Dr. Hernandez’s permit, counter-signatures were not required for “[prescriptions and orders written by a permit holder *84in the in-patient setting.” As a resident, Dr. Hernandez supervised interns, cared for patients, and made diagnoses.

To a patient or visitor at a hospital, a resident in his or her white coat is indistinguishable from any other physician. In sum, a resident is more than just a medical student. A resident in a modern hospital is an integral part of the health-care team.

Overlook Hospital valued Dr. Hernandez’s services sufficiently to agree to pay her $35,000.00 per year, grant her four weeks vacation, and provide her with professional liability and life insurance. To characterize the termination of her residency as involving only academic freedom is to distort reality.

As the Chancery Division explained:

[T]he effect of a resident’s termination from a residency program [is] substantially similar to that of a physician being terminated from hospital staff. In both cases the resident as well as the physician have tarnished records affecting their professional reputations. Such a termination would indeed adversely impact on the likelihood of the resident being accepted into another residency program. This result would prejudice the resident’s right to become licensed, board certified and practice in his or her area of specialty. Similarly, the prejudicial information on the physician’s record may result in his or her denial of medical staff appointment at other hospitals. Having found that the effect and stigma of a resident being terminated from a residency program is substantially the same as a physician being terminated from hospital staff, it follows that a resident should be granted the same fundamental fairness at a hospital hearing as is afforded a physician in a termination proceeding.
[ 291 N.J.Super. at 473-74, 677 A.2d 811.]

Licensed physicians possess the right to counsel at hearings to terminate their hospital privileges. Garrow v. Elizabeth Gen. Hosp. & Dispensary, 79 N.J. 549, 566, 401 A.2d 533 (1979); Zoneraich v. Overlook Hosp., 212 N.J.Super. 83, 91, 514 A.2d 53 (App.Div.), certif. denied, 107 N.J. 32, 526 A.2d 126 (1986). The critical question here is not whether a residency is purely academic, but whether the academic aspect of a residency so outweighs all other considerations that the judiciary should deprive a medical resident of the right to counsel at a hearing to terminate her residency.

*85The majority accepts the premise that a staff physician enjoys the right to counsel at a hearing to terminate his or her privileges. It fears, however, that by according the same right to a resident, “[t]he procedure would become complicated, legalistic, and time consuming and expeditious review of academic judgments would be severely hindered.” Ante at 80, 692 A.2d at 976. Those fears are exaggerated.

The presence of counsel to review records, advise the resident, and to present evidence need not unduly protract a proceeding to terminate a resident. In the present case, for example, the record reveals counsel’s presence did nothing to confirm the majority’s fears. Dr. Hernandez’s lawyer presented no witnesses and did not cross-examine the hospital’s witnesses. His presence, however, assured her that the proceeding was fair, an assurance that takes on added importance in view of the Hospital’s ultimate decision to terminate her residency.

The majority itself harbors misgivings about its result. Without explanation, it recognizes that a resident would be entitled to a right to counsel if the resident’s termination were “motivated by reasons which violated the resident’s Civil Rights. In such cases, the right to counsel at a resident’s termination proceeding would be appropriate to vindicate those substantive rights and protect the public from discriminatory hiring and termination practices.” Ante at 81, 692 A.2d at 977. Likewise, a resident would be entitled to counsel if “the dismissal was motivated by bad faith or ill-will unrelated to academic performance.” Ibid. I agree with those conclusions, but fail to see how the presence of counsel at a proceeding to terminate a residency for such reasons would be any less time-consuming or complicated than a termination proceeding based on the resident’s performance. For some people, the right to work or to continue in a profession is as important as a civil right.

The Accreditation Council for Graduate Medical Education of the American Medical Association has reached a similar conclusion. It recommends that the Guidelines for Resident Agreement *86or Contracts should provide for grievance procedures that include “the right of the resident to counsel.” If the medical profession recognizes that residents are entitled to counsel at termination proceedings, it ill behooves the highest court of this State to reach a contrary conclusion.

The majority’s calculus does not reveal any appreciation for the inequality of the contest between a hospital and a resident. The hospital has virtually limitless resources — including administrators, physicians, and lawyers — at its disposal. The resident stands alone. Many residents are burdened with debt and other obligations. Their status in relationship to the hospital is one of dependence, of an inferior to a superior authority.

Traditionally, courts try to assure a level playing field for contestants in administrative and judicial proceedings. Here, however, the majority is content to ignore the inequality between the hospital and the resident. To achieve this untoward result, the majority relies on exaggerated notions of academic freedom and misplaced fears about the conduct of lawyers in such proceedings.

I would affirm the judgment of the Appellate Division.

Justices HANDLER and STEIN join in this opinion.

For reversal — Chief Justice PORITZ, and Justices O’HEARN, GARIBALDI and COLEMAN — 4.

For affirmance — Justices HANDLER, POLLOCK and STEIN — 8.