University of Southern California v. Superior Court

Opinion

ZEBROWSKI, J.

This case involves a “Resident Evaluation Committee” which evaluates physician-residents enrolled in a postgraduate surgical training program. Evidence Code section 1157 1 generally exempts from discovery the proceedings and records of hospital quality evaluation committees or peer review committees. The issue in this case is whether section 1157 exempts from discovery the proceedings, written evaluations and related records of the Resident Evaluation Committee. The answer is yes.

Plaintiff Dorothy E. Comeau is a licensed physician. In 1992, she enrolled in a postgraduate…