Black doctor loses discrimination claim against Oakwood hospital

John Armstead's obstetrical privileges were terminated by Oakwood Healthcare.  The hospital claimed the termination resulted from Armstead's excessive number of malpractice claims and its resulting liability exposure, however, Armstead claimed that the related medical malpractice claims were generated by hospital negligence.  He attached peer review documents to his pleadings in an attempt to prove hospital culpability.  At the Hospital's demand, the trial court ordered the removal of the peer review documents from the pleadings, holding that they were confidential investigations and not admissible in a civil proceeding.  It also concluded that Armstead's claim was properly dismissed because he did not prove disparate treatment on the basis of race.  The Court of Appeals agreed.