Hassan v. Mercy American River Hospital

BROWN, J., Concurring and Dissenting.

I agree with the majority that the privilege conferred on persons by Civil Code section 43.8 (hereafter all statutory references are to the Civil Code) applies to entities as well as humans. However, I disagree with the majority’s conclusion that section 43.8 provides only qualified immunity.

The purpose of the 1990 amendment was to increase the immunity conferred by section 43.8, as the majority acknowledges. (Maj. opn., ante, at p. 719.) “As originally enacted in 1974, the section 43.8 privilege was qualified rather than absolute. (See Hackethal v. Weissbein (1979) 24 Cal.3d 55, 60 [154 Cal.Rptr. 423, 592 P.2d 1175]; Dorn v. Mendelzon [(1987)] 196 Cal.App.3d [933,] 943 [242 Cal.Rptr. 259]; see also Moore v. Conliffe (1994) 7 Cal.4th 634, 671 [29 Cal.Rptr.2d 152, 871 P.2d 204] (dis. opn. of Baxter, J.).) Before it was amended in 1990, section 43.8 read: ‘[T]here shall be no monetary liability on the part of, and no cause of action for damages shall arise against, any person on account of the communication of information in the possession of such person to any hospital [or] hospital medical staff . . . when such communication is intended to aid in the evaluation of the qualifications, fitness, character, or insurability of a practitioner of the healing or veterinary arts and does not represent as true any matter not reasonably believed to be trued (As amended by Stats. 1983, ch. 1081, § 2, pp. 3864-3865, italics added.) Thus, before the 1990 amendment, the privilege was expressly conditioned on the communicator’s reasonable belief in *725the truth of the information conveyed. The 1990 amendment removed the above italicized language expressly imposing this condition. (Stats. 1990, ch. 1597, § 30, p. 7697.)” (Maj. opn., ante, at p. 719.)

The issue before us, as the majority states, is “whether, by removing from section 43.8 the words ‘and does not represent as true any matter not reasonably believed to be true,’ the Legislature intended to make the privilege absolute, or whether the privilege is still qualified in light of the remaining requirement that the communication must have been ‘intended to aid in the evaluation of the qualifications, fitness, character, or insurability of a practitioner ....’” (Maj. opn., ante, at p. 719.)

The majority concludes the section 43.8 privilege remains qualified. “Because false information of any sort has no value in evaluating a medical practitioner, the communication of information known to be false cannot be intended to help or assist in that evaluation, or, in other words, an intent to deceive is inconsistent with an intent to aid. Thus, proof that the communicator knew the information to be false when it was conveyed establishes malice sufficient to defeat the qualified section 43.8 privilege.” (Maj. opn., ante, at p. 723.)

The crucial misstep in the argument the majority makes in support of its conclusion is assuming that intended, as used in section 43.8, refers to the intent of the person providing the communication. (Maj. opn., ante, at p. 720.)

The Legislature was, instead, referring to the intent of the hospital or hospital staff in soliciting the communication, namely, that the information is being sought to aid in an evaluation of a practitioner’s fitness, character, or insurability. That is what Justice Hull was driving at in his concurring and dissenting opinion below. “[T]he words refer to and describe the nature and subject matter of the proceedings in which the communication is made, not the state of mind of the communicator.”

The validity of this construction is demonstrated by Dorn v. Mendelzon, supra, 196 Cal.App.3d 933 (Dorn). In Dorn, the plaintiff sued for defamation, among others, a hospital administrator named Manley. The plaintiff had applied for staff privileges at Centinela Hospital Medical Center (Centinela). Learning of a Board of Medical Quality Assurance report with regard to the restriction of plaintiff’s staff privileges at Broadway Hospital (Broadway), the Centinela credentials committee wrote a letter of inquiry to Manley, who was the administrator of a hospital that had purchased Broadway’s assets. It was Manley’s response to Centinela that the plaintiff claimed to be defamatory. Because of the context in which Manley made the challenged communication, the Court of Appeal held that the then qualified privilege applied. “The *726Manley letter was certainly intended to aid in the evaluation of plaintiff’s qualifications, and plaintiff does not contend otherwise. In fact, the letter was solicited by Centinela’s credentials committee for the purpose of assisting its consideration of plaintiff’s application for staff privileges. Thus, the qualified immunity for communications evaluative of medical practitioners set forth in section 43.8 is applicable.” (Dorn, at p. 944.)

“The Legislature, of course, is deemed to be aware of statutes and judicial decisions already in existence, and to have enacted or amended a statute in light thereof. (People v. Overstreet (1986) 42 Cal.3d 891, 897 [231 Cal.Rptr. 213, 726 P.2d 1288].) Where a statute is framed in language of an earlier enactment on the same or an analogous subject, and that enactment has been judicially construed, the Legislature is presumed to have adopted that construction. (Union Oil Associates v. Johnson (1935) 2 Cal.2d 727, 734—735 [43 P.2d 291].)” (People v. Harrison (1989) 48 Cal.3d 321, 329 [256 Cal.Rptr. 401, 768 P.2d 1078].) Therefore, the Legislature, in amending section 43.8, must be presumed to have had Dorn in mind, and to have understood, consistent with Dorn, that the phrase intended to aid referred to the intent in soliciting the communication, not the intent in providing it.

The majority seeks support for its interpretation in the final sentence of section 43.8, which states: “The immunities afforded by this section and by Section 43.7 shall not affect the availability of any absolute privilege which may be afforded by Section 47.” “If section 43.8 itself conferred an absolute privilege,” the majority argues, “there would be no reason for legislative concern that the section 43.8 privilege not affect the availability of the absolute privilege under section 47. This legislative concern necessarily implies that the section 43.8 privilege is more limited than the section 47 privilege, or, in other words, that the section 43.8 privilege is qualified rather than absolute.” (Maj. opn., ante, at p. 721.)

The majority has misconstrued the significance of the final sentence of Civil Code section 43.8. This is demonstrated by the fact that Business and Professions Code section 2318 , which clearly creates absolute immunity, concludes with the same sentence.

Business and Professions Code section 2318 provides: “In addition to any immunity afforded by Sections 43.8 and 47 of the Civil Code, if applicable, any person, including, but not limited to, a physician and surgeon, hospital, health facility as defined in Section 1250 of the Health and Safety Code, nursing home, convalescent home, peer review body as defined in Section 805, medical society, professional association, patient, nurse, or other healing arts licensee who provides information to the board, to the California Board of Podiatric Medicine, or to the Department of Justice indicating that a board *727licensee may be guilty of unprofessional conduct or may be impaired because of drug or alcohol abuse or mental illness, shall not be liable for any damages in any civil action on account of the communication of that information to the board. The immunities afforded by this section shall not affect the availability of any absolute privilege which may be afforded by Section 47 of the Civil Code.” (Stats. 1990, ch. 1597, § 22, pp. 7694-7695.)

Civil Code section 43.8 was amended (Stats. 1990, ch. 1597, § 30, p. 7697) and Business and Professions Code section 2318 was enacted (Stats. 1990, ch. 1597, § 22, pp. 7694-7695) by Senate Bill No. 2375 (1989-1990 Reg. Sess.). They were elements of a comprehensive reform of California’s system of discipline against medical practitioners, a system the Legislature declared to be “inadequate to protect the health, safety, and welfare of the people of California against incompetent or impaired physicians.” (Stats. 1990, ch. 1597, § 1, p. 7683.) The immunity provided by Business and Professions Code section 2318 is clearly absolute: “[A]ny person . . . who provides information to the board . . . indicating that a board licensee may be guilty of unprofessional conduct or may be impaired . . . shall not be liable for damages in any civil action on account of the communication of that information to the board.” And yet, like the final sentence of Civil Code section 43.8, the final sentence of Business and Professions Code section 2318 provides that the immunities afforded by it “shall not affect the availability of any absolute privilege which may be afforded by Section 47 of the Civil Code.”

Finally, the majority fails to give sufficient weight to the important public policy served by according witnesses an absolute privilege against defamation actions, namely, that such a privilege is established, not for the benefit of witnesses, but for that of the public and the advancement of the administration of justice, to prevent witnesses from being deterred from coming forward and testifying to the truth by the fear of having actions brought against them. (Hackethal v. Weissbein (1979) 24 Cal.3d 55, 65 [154 Cal.Rptr. 423, 592 P.2d 1175] (dis. opn. of Tobriner, J.).) The majority summarily dismisses this consideration, saying that competing public policy arguments are best resolved by the Legislature. (Maj. opn., ante, at p. 723.) I agree in principle, of course, on the Legislature’s primacy in such matters. My concern is that the Legislature has already made its decision on this question, in favor of absolute immunity, and that we are failing to implement it.