The Healthcare Quality Improvement Act of 1986 (HCQIA) of the United States was introduced by Congressman Ron Wyden from Oregon. (Title 42 of the United States Code, Sections 11101 - 11152)
It followed a federal antitrust suit by a surgeon against an Astoria hospital and members of its clinic in which he claimed antitrust actions were effected through the mechanism of peer review in the hospital. He claimed that a general surgeon of the clinic initiated the action due to an ongoing dispute between him and the clinic.
He prevailed in a jury trial. (The antitrust suit was later overturned by the U.S. Court of Appeals on the grounds that existing Oregon statutes already protected the peer review committee members from prosecution and that these protections should extend to federal antitrust suits brought by individuals for monetary (but not injunctive) relief.)
Soon thereafter Congressman Wyden introduced HCQIA in an effort to extend state peer review immunities on a federal level.