Parungao v. Community Health Systems, Inc.

Dist. Ct. did not err in granting defendants-hospital officials’ motion to dismiss on res judicata grounds plaintiff-physician’s action alleging that defendants initiated sham peer-review process that led him to seek other employment and then failed to confirm with prospective employers that he was member of hospital staff in good standing. Record showed that plaintiff had previously filed related action against different member of hospital staff, alleging that said defendant defamed him by making false statements to plaintiff’s prospective employers that suggested that plaintiff had been subject to some type of non-disciplinary action related to his professional conduct. All three elements of res judicata were present, where: (1) prior action resulted in order dismissing case with prejudice for failure to state valid cause of action, which qualified as final judgment on its merits; (2) both causes of action arose out of series of statements made by both sets of defendants around time plaintiff resigned and sought other employment, which, according to plaintiff, made it difficult for him to get another job; and (3) both sets of defendants were in privity where legal interests in said defendants were aligned, especially where plaintiff had pleaded that defendants in instant case were vicariously liable for series of alleged defamatory letters written by defendant in prior case.