Stafford v. Attending Staff Association of LAC + USC Medical CenterAnnotate this Case
The Court of Appeal affirmed the trial court's grant of plaintiff's petition for writ of mandate seeking an order directing the Association to complete plaintiff's administrative proceeding. Plaintiff, a physician whose clinical privileges were terminated by the Association, was denied an administrative hearing because the Association believed that he had withdrawn or abandoned his right to the hearing through his communications and conduct, and by filing an unsuccessful action in superior court.
The court held that the Association misinterpreted the doctrine of exhaustion of administrative remedies. The court clarified that the doctrine precludes premature lawsuits, but it did not mean that filing a premature lawsuit necessarily waives an administrative remedy. The court also held that substantial evidence supported the trial court's finding that plaintiff did not withdraw his administrative appeal. Finally, the trial court did not misapply the burden of proof on the Association to show that plaintiff abandoned or withdrew his appeal, rather than requiring plaintiff to prove that the Association failed to fulfill a legal duty in proceeding with the appeal.