Strong v. Brakeley
Annotate this CasePlaintiff Kevin Strong and Defendants Rebecca Brakeley and Jonathan Bausman were all physicians licensed to practice medicine in Maine. Plaintiff filed a complaint against Defendants alleging that certain negative statements made by them on a credentials verification system’s questionnaires caused St. Mary’s Regional Medical Center to deny him staff privileges. Plaintiff asserted claims for defamation and tortious interference with a business relationship and sought punitive damages. Defendants moved to dismiss the complaint on the ground that they were entitled to absolute immunity for their statements pursuant to 24 Me. Rev. Stat. 2511. The superior court agreed and entered summary judgment in favor of Defendants. The Supreme Judicial Court affirmed, holding that Defendants’ answers to the questionnaires “constituted eligible reports by eligible reporters made for the purpose of assisting a board, authority, or committee in carrying out its statutory duties as a matter of law within the plain meaning of section 2511(3).”
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