The Illinois Supreme Court reversed a controversial appellate decision without reviewing some critical issues related to medical staff bylaws. The court has thus left open these issues. In Garibaldi v. Applebaum, an appellate court deviated from long-standing precedence and statutory immunities by holding that hospital bylaws constitute a contract between medical staff and the hospital. The court also found that a violation of bylaws provides a physician with a claim for damages against the hospital.The Supreme Court reversed the decision on unrelated grounds. The ruling leaves open the question of whether damages are available for bylaws violations.