Is there any federal obligation that a doctor subject to a hospital peer review be represented by an attorney?

Secondly, assuming there is state action so as to require compliance by the state with federal due process, appellants cite no case in a hospital peer review context holding that federal due process requires that a doctor subject to such a review be afforded an opportunity to be represented by an attorney. Indeed, for the reasons we have discussed, fundamental fairness does not require legal representation. Essentially there is no real difference between fair procedure and due process rights. The distinction is one of origin rather than one of the extent of the protection afforded to the individual. "[T]he essence of both rights is fairness." ( Applebaum v. Board of Directors, supra, 104 Cal.App.3d 648, 657, 163 Cal.Rptr. 831.)