Muse v. Charter Hospital of Winston-Salem, Inc. case brief

Muse v. Charter Hospital of Winston-Salem, Inc. case brief summary
452 S.E.2d 589 (1995)

CASE SYNOPSIS

Defendants, hospital and parent corporation, appealed a judgment of the Guilford County Superior Court (North Carolina), which awarded plaintiff estate compensatory and punitive damages for the wrongful death of the decedent as the result of hospital's practice of discharging patients when their insurance expired.

CASE FACTS
The hospital and parent corporation contended that the estate's theory of liability did not exist under the law and that the separate awards of punitive damages against them were improper. The court found that the decedent had committed suicide after being discharged from hospital.

DISCUSSION

• The court affirmed the compensatory award, but reversed and remanded the punitive awards. 
• After concluding that the hospital had a duty not to institute a policy or practice which required that patients be discharged when their insurance expired and which interfered with the medical judgment of the doctor, the court found sufficient evidence that the hospital's practices were below this standard of care and were willful or wanton. 
• The court determined, however, that the trial court had erred in instructing the jury that it could impose punitive damages against both the hospital and parent corporation because after finding that the hospital was an instrumentality of the parent corporation, the two should have been treated as one in assessing liability.

CONCLUSION

The court affirmed the compensatory award for the estate against the hospital and parent corporation in a wrongful death action, but reversed and remanded the punitive awards against both the hospital and parent corporation.

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