Holmes v. East Cooper Community Hospital
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Appellant Cynthia Holmes, MD was previously a member of the consulting medical staff of the Respondent East Cooper Community Hospital, Inc. During the relevant time period, Appellant was a member of the Hospital's medical consulting staff, appointed in two-year increments. In October 2006, she submitted a reappointment application seeking advancement in medical staff category and clinical privileges to perform surgery. The Hospital's credentialing committee found Appellant unqualified for the level of privileges she requested. Appellant received administrative review of this decision, and was ultimately reappointed as consulting medical staff for another two-year term. In October 2008, Appellant submitted another reappointment application requesting advancement. This time, the Hospital determined that Appellant's application was incomplete and requested she voluntarily resign from the medical staff without appellate rights under the medical staff bylaws. This appeal stemmed from the Hospital's privileging decisions. Respondent successfully moved summary judgment on several grounds, including that the circuit court lacked subject matter jurisdiction to review the medical staff privileging decisions of a private hospital. Thereafter, Respondent filed a motion for sanctions under the Frivolous Civil Proceedings Sanctions Act (FCPSA), arguing, inter alia, that the circuit court should sanction Appellant for "seeking adjudication of claims over which this Court does not have jurisdiction" and "raising issues which have been previously adjudicated against [Appellant] and in [Respondents'] favor." Appellant appealed the sanctions order, arguing the circuit court erred in awarding sanctions against her, and challenging the Act's constitutionality. Finding no reversible error, the Supreme Court affirmed the circuit court's decisions.
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