Fine v. University of Utah
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In this case, a doctor, Dr. Gabriel Fine, sued the University of Utah School of Medicine, alleging that the University deprived him of his clinical privileges without following the procedures required by its bylaws. The University moved for summary judgment, pointing to a provision in its bylaws where Dr. Fine had agreed not to sue "for any matter relating to appointment, reappointment, clinical privileges, or the individual’s qualifications for the same." The district court granted summary judgment in favor of the University, agreeing that Dr. Fine had released his claims against the University.
Dr. Fine appealed the decision, arguing that the district court erred in interpreting the release to apply to his case. He asserted that the release only applied to actions taken during a formal review process and his claims arose from actions taken during an informal process.
The Supreme Court of the State of Utah disagreed with Dr. Fine's argument. The court interpreted the release using its traditional tools of contract interpretation and found no textual justification for limiting the release's application only to actions taken during the formal review process. The court held that Dr. Fine’s claims against the University fell within the scope of the release and therefore affirmed the district court's decision.
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