North Colorado Medical Center, Inc. v. Nicholas

We granted certiorari to review the court of appeals' decision in Nicholas v. North Colorado Medical Center, Inc., 12 P.3d 280 (Colo.App.1999) (Nicholas II). 1 In reversing the trial court's orders for summary judgment, the court of appeals held that the peer review process in a private hospital constitutes state action for the purpose of 42 U.S.C. § 1988. The court of appeals also held that the peer review process did not conform to the requirements of the Colorado Professional Review Act, sections 12-36.5-101 to -208, 4 C.R.S. (2000) (CPRA), and the Health Care Quality Improvement Act, 42…