Wednesday, November 13, 2013

Thompson v. Nason Hospital case brief

Thompson v. Nason Hospital case brief summary
591 A.2d 703 (1991)


CASE SYNOPSIS
Appellant hospital sought review of the judgment of the Superior Court (Pennsylvania), which reversed the trial court's grant of summary judgment in favor of appellant. Appellant contended, inter alia, the lower appellate court erred in adopting a theory of corporate liability with respect to a hospital; the lower court erred in finding that there was a material issue of fact with respect to the corporate liability of appellant.

CASE FACTS

Appellee patient and her husband brought a personal injury action against appellants, hospital and physician, alleging appellee patient's injuries were the direct and proximate result of the negligence of appellant hospital acting through its agents, servants, and employees in failing to adequately examine and treat her, in failing to follow its rules relative to consultations, and in failing to monitor her conditions during treatment. The trial court entered a summary judgment dismissing appellant hospital.

DISCUSSION

  • Appellees sought review, and the lower appellate court reversed. 
  • Appellant then sought the instant review. 
  • The court affirmed the lower appellate court, and adopted as a theory of hospital liability the doctrine of corporate negligence or corporate liability under which the hospital was liable if it failed to uphold the proper standard of care owed its patient. 
  • The court further found that there was a sufficient question of material fact as to whether appellant was negligent in supervising the quality of medical care appellee patient received, such that the trial court could not have properly granted summary judgment on the issue of corporate liability.

CONCLUSION
The court affirmed the lower appellate court decision which reversed the trial court's order granting summary judgment in favor of appellant hospital. The court held that there were genuine issues of material fact as to whether appellant hospital provident negligent supervision of the appellee patient's medical care.

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