Defendants complied with their bylaws in denying plaintiff a renewal of his contract and promotion in their residency training program. They are therefore immune from civil liability under Public Health Law § 2805-j (2), which became effective before plaintiff commenced this action, albeit after he left the training program, and which therefore applies (cf., Matter of St. Vincent's Hosp. & Med. Ctr. v New York State Div. of Hous. & Community Renewal...
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