Healthcare and Tort Liability: Second Circuit Affirms Dismissal of Doctor’s Libel and Tortious Interference Claims

Verrill Dana successfully represented Northwestern Medical Center and Quorum Health Resources in an appeal the United States Court of Appeals for the Second Circuit. Doctor Raymond Long alleged that Northwestern and Quorum had filed a false notice with the National Provider Review Database after Long had resigned from the hospital while under investigation. The District Court dismissed Long’s complaint against Northwestern and Quorum on the grounds that aspects of his complaint were barred by res judicata and that he invited the harm of which he complained. The Second Circuit affirmed on all grounds. The case is Long v. Quorum Health Resources, 590 Fed. Appx. 103 (2d Cir. 2015).