Young v. Huntsville Hospital (1992, Supreme Court of Alabama)
Rule of Law: Hospital owes a duty to protect its sedated or anesthetized patients from third-party criminal acts (because there is a special relationship)
Facts: Patient (P) at Huntsville Hospital (D) was admitted for treatment of kidney stones and was sedated. She was allegedly assaulted by a male trespasser who had previously trespassed in the Hospital. Patient was assaulted at 6 a.m. which was outside of the posted visiting hours. The hospital had four security guards for the 450 bed hospital. Patient claims emotional distress and alleges a negligent and/or wanton failure to protect her from the criminal act (specifically claiming a special relationship, as she was sedated)
History: Trial court entered directed verdict in favor of D and judge overruled P's motion for new trial, probably due to D's lack of legal obligation to P.
Issue(s): Whether a hospital owes a duty to protect its sedated or anesthetized patients from third-party criminal acts
Holding: The "special relationship" between a sedated patient (who is dependent upon the hospital) and a hospital does create a duty on the hospital's part to protect the patient from criminal acts of third parties.
Reasoning: There is evidence that the relationship between the sedated patient and the hospital is a "special relationship circumstance." Special relationships hinge on "dependence or mutual dependence" among parties. In this case, after applying a dependence test, the court concluded the sedated patient is logically dependent on the hospital for "basic bodily protection and care." This type of relationship imposes a duty on the hospital to protect the dependent patient.
In this case the court thought that this act was foreseeable, but not wanton. The case was awarded a new trial in trial court based on the fact that the hospital did owe a duty to the patient.