In Anton v. San Antonio Community Hosp. (1977) 19 Cal.3d 802, a licensed physician and surgeon was notified that his hospital privileges had been suspended. There followed three hearings, as provided in hospital bylaws. The first, a preliminary hearing which is not described in the opinion; the second, a formal hearing before a judicial review committee at which evidence was presented and a court reporter was present and transcribed all proceedings; and, finally, an appellate review before the board of directors. The board upheld the decision of the judicial review committee, which had sustained the suspension, and recommended that Anton not be reappointed to the medical staff. Plaintiff contended, inter alia, that a hospital bylaw placing the burden of going forward with the evidence and the burden of proof upon him violated the common law requirement of a minimal fair procedure which is applicable to private hospitals. ( Pinsker v. Pacific Coast Society of Orthodontists (1974) 12 Cal.3d 541, 549-557 116 Cal.Rptr. 245; Ascherman v. Saint Francis Memorial Hosp. (1975) 45 Cal.App.3d 507, 511.) The Supreme Court upheld the bylaw, stating, "We cannot conclude that the adoption and application of the bylaw here in question constitutes an abuse of the indicated discretion. Although it appears to place the initiative with respect to the production of evidence upon the party requesting the hearing in light of an adverse administrative recommendation, and although it further appears to require that the recommendation be sustained absent a 'clear and convincing' showing by that party that it should be overturned, it is clear that the bylaw read as a whole -- especially when viewed in conjunction with the provision setting forth the grounds for appellate review before the governing board . . . -- contemplates a substantial showing on the part of the charging committee in support of its recommendation." ( Anton v. San Antonio Community Hosp., supra, 19 Cal.3d 802, 829-830.)