In Community Hosp. v. Superior Court (1976) 17 Cal.3d 465, the plaintiff, Dr. Kaiman, sued Westlake Community Hospital and numerous individual members of the hospital's board and committees after the hospital revoked her staff privileges. (Westlake, supra, 17 Cal.3d at p. 469.) Her complaint alleged the revocation stemmed from a malicious conspiracy engineered by the named defendants to destroy her medical practice, restrain competition, and intentionally inflict emotional distress upon her. (Id. at p. 470.) Kaiman further alleged that "the revocation of her privileges at Westlake 'was pursued and perfected in a manner contrary to established principles of fairness and justice,' and contrary to Westlake's own bylaws and constitution." (Ibid.) The Westlake defendants moved for summary judgment. The supporting affidavits showed the hospital's credentials committee recommended the revocation of Kaiman's staff privileges, after which the hospital notified Kaiman of the decision and of her right to request a hearing before a judicial review committee. (Westlake, supra, 17 Cal.3d at pp. 471-472.) Kaiman requested a hearing, at which she called witnesses and introduced documentary evidence. After the hearing, the hospital informed Kaiman that the judicial review committee had determined her staff privileges should be revoked and advised Kaiman of her right to appeal the decision to the hospital's board of directors. Kaiman appeared before the board and presented her objections, after which the board affirmed the judicial review committee's decision. (Ibid.) The Westlake defendants asserted the foregoing facts conclusively established the invalidity of Kaiman's suit. Among other things, the defendants argued Kaiman "could not 'collaterally attack' the hospital's revocation decision by a tort action, but could only seek damages after she had succeeded in a 'direct attack' on the quasi-judicial hospital decision in a mandamus proceeding." (Westlake, supra, 17 Cal.3d at p. 473.) The trial court denied the defendants' summary judgment motion. (Ibid.) The Supreme Court reversed. The Supreme Court concluded Kaiman's tort action against the hospital and individual board and committee members was "premature" because Kaiman "did not challenge the revocation through a mandamus proceeding." (Westlake, supra, 17 Cal.3d at p. 485.) The high court analogized this condition to a comparable requirement in malicious prosecution actions, which can only be maintained after the allegedly maliciously initiated proceeding has terminated favorably for the plaintiff. (Id. at p. 483.) Though acknowledging the distinctions "between public and private administrative proceedings," the court concluded that the "general policy underlying the 'favorable termination' requirement in malicious prosecution actions applies in the present context." (Id. at pp. 483-484.) The court explained: "As in a malicious prosecution action, plaintiff's position rests on a contention that defendants intentionally and maliciously misused a quasi-judicial procedure in order to injure her; such a claim is necessarily premised on an assertion that the hospital's decision to revoke plaintiff's privileges was itself erroneous and unjustified. Although a quasi-judicial decision reached by a tribunal of a private association may not be entitled to exactly the same measure of respect as a similar decision of a duly constituted public agency citation, we believe that so long as such a quasi-judicial decision is not set aside through appropriate review procedures the decision has the effect of establishing the propriety of the hospital's action. . Accordingly, we conclude that plaintiff must first succeed in overturning the quasi-judicial action before pursuing her tort claim against defendants." (Id. at p. 484.) The Westlake court also identified important policy considerations that are advanced by requiring mandamus review before permitting an action for damages: "In our view, the above requirement accords a proper respect to an association's quasi-judicial procedure, precluding an aggrieved party from circumventing the established avenue of mandamus review. In addition, this result will simplify court procedures by providing a uniform practice of judicial, rather than jury, review of quasi-judicial administrative decisions." (Westlake, supra, 17 Cal.3d at p. 484, citing 1094.5.) Finally, the court observed, "this procedure affords a justified measure of protection to the individuals who take on, often without remuneration, the difficult, time-consuming and socially important task of policing medical personnel," yet remain potentially subject to liability should the court determine "in a mandamus proceeding that an association's quasi-judicial decision cannot stand, either because of a substantive or procedural defect." (Westlake, at p. 484.)