Q: What were the facts in the case Treister v. American Academy of Orthopeadic?
Treister v. American Academy of Orthopeadic:
a. Plaintiff sued b/c he was denied admission in the Orthopaedic Surgeon Association. Plaintiff claimed that membership was a “necessity” for recognition by hospitals in his specialty.
b. The application process including distributing forms to physicians requesting information about his reputation and credentials. The association received adverse information re: the plaintiff. But he did show he was a member of several hospitals and was a professor. He tried to rebut the claims but the association rejected his application.
c. Plaintiff claims the association violated their bylaws b/c they required review by a body, etc. He only had an interview with one person and had no chance to rebut the adverse information.
d. Plaintiff claims he was singled out for testifying on behalf of plaintiffs.
e. HELD: courts can review application procedures of a private association ONLY when there is an “economic” necessity. Short of the economic requirement, the court will not interfere in the affairs of a private association.
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