In Sadler v. Dimensions Healthcare Corp., 836 A.2d 655 (Md. 2003), the court rejected an administrative law "substantial evidence" standard of review and instead applied a corporate law "business judgment" rule to review of a medical staff decision.  The court reasoned that, in contract or tort actions, private corporations are not owed the same type of deference given to government agencies.

In Wojewski v. Rapid City Regional Hospital Inc. (8th Cir. 2006), the court held that a medical staff physician is not an employee under the ADA).   

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