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.
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