Belnap v. Howard, 2019 UT 9 (February 28, 2019)

In an action a surgeon brought against physicians for defamation and tortious interference with prospective economic relations, the surgeon urged a bad-faith exception to the peer review privilege contained in Utah R. Civ. P. 26(b)(1), and argued he was entitled to discovery of statements made by the physicians in that context.  In upholding the claim of privilege, the Utah Supreme Court held that under a plain language analysis of the rule, the peer review privilege unambiguously protected all information provided at any stage of a peer review, and there was no bad faith exception.