Klaine v. Southern Illinois Hospital Services (2016 IL 118217)

Background -

The plaintiff filed a negligent credentialing medical malpractice lawsuit against a physician and two hospitals where he was a member of the medical staff. Although the hospital produced almost 2,000 pages of information in response to a discovery request, it refused to deliver two groups of documents which contained three of the physicians' applications submitted in 2009, 2010 and 2011 (Group Exhibit F) and "procedure summaries and case histories" (Group Exhibit J), arguing that they were privileged under the Illinois Medical Studies Act (735 ILCS 5/8-2101), (MSA) and the Health Care Professional Credentials Data Collection Act (410 ILCS 517/1 et seq.) (Credentials Act).