## Facts

- St. John Regional Medical Center, Inc. operated a nonprofit hospital in Huron, South Dakota.
- The St. John’s Hospital Medical Staff was an organized group of licensed physicians holding staff privileges at the hospital.
- The hospital and staff operated under “Bylaws, Rules, and Regulations of St. John’s Hospital Medical Staff,” which governed appointments, clinical privileges, staff organization, and discipline/suspension procedures.
- The medical staff bylaws required that amendments receive medical staff approval before becoming effective.
- The hospital’s board sought bylaw revisions that would ease suspension/termination of staff members and require hospital approval of all medical-staff officers.
- The medical staff did not approve the proposed changes through the amendment process.
- The board then adopted a new set of medical staff bylaws without medical staff approval.
- The medical staff filed a declaratory judgment action to invalidate the unilaterally adopted bylaws and to require compliance with the existing bylaws and their amendment procedure.
- The trial court ruled for the medical staff, concluding the bylaws created enforceable obligations and that the medical staff could sue as an entity.

## Issues

1. Whether the medical staff bylaws constituted a binding contract between the hospital and the medical staff that the hospital could not unilaterally alter contrary to the bylaws’ amendment procedure.
2. Whether the unincorporated medical staff had sufficient attributes of a legal entity to maintain a declaratory judgment action in its own name.

## Decision

- The South Dakota Supreme Court affirmed the declaratory judgment for the medical staff.
- The court held the medical staff bylaws had contractual force in the hospital–physician relationship and could not be unilaterally replaced in disregard of the agreed amendment process.
- The court held the medical staff, though unincorporated, had sufficient organizational identity and recognition under the hospital’s governance structure to sue for declaratory relief.

## Legal Principles

- Hospital medical staff bylaws may be enforceable as a contract when they are adopted with hospital assent, relied upon in granting and governing staff privileges, and set mutually accepted procedures affecting rights and obligations.
- A hospital may be bound by bylaw-based amendment procedures and may not unilaterally impose conflicting bylaws where mutual approval is required.
- An unincorporated association may have capacity to sue when it is an identifiable, organized body recognized by governing documents and the dispute concerns its collective rights and duties.
- Declaratory judgment is available to resolve disputes over the parties’ rights and obligations under governing bylaws.

## Conclusion

The court upheld declaratory relief enforcing medical staff bylaws as contract-like commitments limiting unilateral hospital action and recognized the medical staff’s capacity, as an organized unincorporated association, to litigate its bylaw-based rights.


St. John’s Hosp. Med. Staff v. St. John Reg’l Med. Ctr., Inc., 245 N.W.2d 472 (S.D. 1976)