Exhaustion of Administrative Remedies Requirement Reaffirmed
In Vranos v. Skinner, the Massachusetts Appeals Court reaffirmed the doctrine of exhaustion of administrative remedies. The Court affirmed the dismissal of the lawsuit arising out of a summary suspension of a physician’s staff privileges. The bylaws of Franklin Medical Center contained the typical internal grievance procedures. Dr. Vranos alleged that the hospital had not complied with his procedures, but the Court held that the fair hearing process was the proper venue for contesting the hospital’s actions, including an allegation of violation of the bylaws procedures. The Court stated that the hospital’s “failure to follow the provisions of the bylaws was a basis for evoking the bylaws’ appellate review procedures, nor grounds for ignoring them.”
