Charles R. Williams v. Santa Rosa Medical Hospital, et al.
- Susan Illston
- 3:25-cv-06118
- U.S. District Court · Northern District of California
- 6
Counsel of record per CourtListener. Firm names are approximate.
Williams v. Santa Rosa Medical Hospital: Judge Illston denied reconsideration of dismissal of Williams’s defamation claims, ruling later disclosures could not support amendment.
Charles R. Williams and Anesthesia and Analgesia Medical Group; the ruling leaves Williams’s request to reconsider the dismissal of his defamation claims denied.
What happened
In Charles R. Williams v. Santa Rosa Medical Hospital, Williams asked the court to reconsider its earlier dismissal of his defamation claims against Anesthesia and Analgesia Medical Group. The earlier dismissal was based on the one-year deadline for defamation claims because the challenged 2023 report was issued more than a year before Williams filed suit.
Williams argued that newly obtained records showed later disclosures of the report to health care entities, creating separate publications with separate deadlines. He asked to amend his complaint to add claims based on those later disclosures. Anesthesia and Analgesia Medical Group opposed the request, arguing that reconsideration was not the proper procedure and that the proposed claims would be barred by California’s litigation privilege.
The court denied the motion for reconsideration. It ruled that Williams was trying to add claims based on later disclosures rather than correct the earlier dismissal, and that amendment would be futile because California’s litigation privilege absolutely protects the reports and later disclosures connected to the medical peer-review process. Judge Susan Illston issued the order.
The detailed version
- Charles R. Williams v. Santa Rosa Medical Hospital, et al. · No. 3:25-cv-06118
- Susan Illston
- Sept. 1, 2026
Background
The court had previously granted Anesthesia and Analgesia Medical Group’s motion to dismiss Charles R. Williams’s second amended complaint. Williams’s defamation claims were dismissed without leave to amend. The court concluded that the August 8, 2023 report attributed to Anesthesia and Analgesia Medical Group was published more than one year before Williams filed his original complaint, making the claims untimely under California’s one-year statute of limitations for defamation claims.
Williams moved for reconsideration of that dismissal. He stated that he obtained a copy of the report on July 1, 2026, and reviewed an updated National Practitioner Data Bank disclosure history on July 15, 2026. That history identified health care entities that had queried reports about him, including queries within one year before he filed the action and additional queries after the action began. Williams argued that each later response to a query was a separate publication and sought permission to amend his complaint to add claims based on those disclosures.
Legal standard
A motion for reconsideration may be granted in unusual circumstances when there is newly discovered evidence, clear error, an intervening change in controlling law, a material difference in facts or law that could not reasonably have been discovered earlier, or a manifest failure to consider material facts or dispositive legal arguments. Such a motion generally may not be used to present arguments or evidence that could reasonably have been raised earlier.
Court’s analysis
The court agreed that Williams’s motion was improperly filed because it did not seek to change the ruling as to the original 2023 publications. Instead, it sought to add allegations concerning later disclosures. The court also held that amendment would be futile.
The court applied California’s litigation privilege, which provides absolute protection for communications made as part of a judicial or other official truth-seeking proceeding. The court stated that the privilege includes communications connected with medical peer-review proceedings and may extend to steps taken before or after such proceedings. Relying on California and federal decisions, the court held that the 2023 reports to the National Practitioner Data Bank and the California Medical Board, as well as later publications responding to queries, were protected by the privilege. The court therefore concluded that Williams could not pursue defamation claims against Anesthesia and Analgesia Medical Group based on those reports.
Disposition
The court DENIED Williams’s motion for reconsideration of the June 26, 2026 order. Judge Susan Illston signed the order on September 1, 2026.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.