Doctor’s Retaliation Suit Fails To Meet 4th, 5th Prongs Of Garcetti
DENVER - A Wyoming doctor failed to show that speaking out about substance abuse at the hospital where he had staff privileges resulted in a “campaign of retaliation” against him, the 10th Circuit U.S. Court of Appeals ruled Nov. 17 (Marvin W. Couch, II, M.D. v. Board of Trustees of the Memorial Hospital of Carbon County, et al., No. 08-8001, 10th Cir.; 2009 U.S. App. LEXIS 25182).
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