## Facts

- Dr. Achilles P. Anton, a licensed physician, held medical staff membership and hospital privileges at San Antonio Community Hospital for about 13 years.
- The hospital’s medical staff, organized under the hospital board’s auspices pursuant to statutory requirements, previously took corrective or disciplinary actions against Anton for failing to complete medical records.
- In October 1973, the medical staff investigated Anton’s hospital practice; a committee reported evidence of poor medical judgment and overutilization, including admissions and tests allegedly lacking medical indication.
- A second committee reviewed consecutive admissions, found chart deficiencies and over/underutilization issues, and recommended action under staff bylaws.
- In December 1973, Anton’s annual reappointment application was withheld.
- In January 1974, the executive and credentials committees summarily suspended his hospital privileges.
- Anton received a preliminary hearing that upheld the suspension, then requested a formal hearing.
- A judicial review committee was appointed under the bylaws; Anton received written notice of specific charges.
- After a formal hearing beginning March 5, 1974, the judicial review committee recommended suspension of privileges and denial of reappointment.

## Issues

1. Whether judicial review of a private nonprofit hospital’s decision revoking a physician’s staff privileges requires the superior court to apply independent judgment or only substantial-evidence review.
2. Whether revocation of staff privileges constitutes a quasi-judicial decision affecting a fundamental vested right that triggers independent-judgment review in mandate proceedings.

## Decision

- The California Supreme Court reversed the judgment denying Anton’s petition for writ relief and remanded.
- The Court held the hospital’s staff-privilege determination was quasi-judicial and affected Anton’s fundamental vested right to continue practicing his profession at the hospital.
- The superior court was required to exercise independent judgment on the evidence, rather than defer under a substantial-evidence test.
- The Court did not decide whether Anton should be reinstated; it directed the trial court to apply the correct standard on remand.

## Legal Principles

- When a quasi-judicial decision substantially affects a fundamental vested right, the superior court must apply independent-judgment review, reweighing the evidence while affording a strong presumption of correctness to the decisionmaker’s findings.
- A private hospital’s peer-review and credentialing actions, when conducted under established bylaws with notice and hearing procedures, can be treated as quasi-judicial for purposes of mandate review.
- A physician’s continued staff privileges and ability to admit and treat patients at a hospital may constitute a fundamental vested right due to its direct impact on professional practice.
- Traditional mandamus may be used to obtain judicial review of a private organization’s quasi-judicial decision affecting important rights, subject to applicable procedural requirements.

## Conclusion

The court required independent-judgment judicial review of a private hospital’s quasi-judicial revocation of a physician’s staff privileges because the decision substantially affected a fundamental vested right, and it remanded for the trial court to reweigh the evidence under that standard.


Anton v. San Antonio Cmty. Hosp., 19 Cal. 3d 802 (Cal. 1977)