Holston v. Sloan
Holston v. Sloan
Opinion of the Court
OPINION
In this administrative law case, Appellant sought relief in the District Court from an order of the Board of Managers of Ward Memorial Hospital which suspended him from privileges at the Hospital. The trial Court denied any relief. We affirm.
Appellant’s active staff membership at Ward Memorial Hospital was summarily suspended after he had been admitted to the Hospital with an apparent drug overdose. Following that suspension, he was accorded a hearing before a Medical Staff Committee, composed of two doctors, under the authority of the by-laws of the Hospital. One doctor recommended that his suspension be made permanent, and the other recommended that his suspension be temporary, pending treatment and certification that he had no problem with drugs. Thereafter, he demanded and received a judicial review before the Board of Managers of Ward Memorial Hospital. Following such hearing, the Board of Managers voted that his suspension of Medical Staff privileges be made permanent, and that his appointment to the Medical Staff be terminated. Appellant then brought this suit, alleging that the decision of the Board of Managers was arbitrary, unreasonable and capricious, and was not supported by substantial evidence, and that he was denied substantive due process of law under the Constitutions of the State of Texas and the United States.
Appellant’s single Point of Error is that the trial Court erred in deciding this action on the basis of the transcript of the proceedings held before the Committee of the Medical Staff and the transcript of proceedings held before the Appellate Review Committee of the Hospital Board of Managers rather than considering a new record made before the trial Court. At the commencement of trial, Appellant sought, and the Court refused, a trial de novo under the substantial evidence rule.
Judicial review of the various administrative agencies has, in some instances, been specifically provided for and, in others, specifically denied by the legislature. Ward Memorial Hospital is a county hospital, organized and existing under the authority of
The judgment is affirmed.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.