Lucy Webb Hayes Natl. Training School v. Geoghegan

Brief Fact Summary.

Defendant was a patient for a considerable length of time at Sibley Memorial Hospital, which is maintained and operated by Plaintiff. The hospital concluded that the patient no longer needed hospital care but can be adequately provided for at a nursing home. The hospital made a formal demand on the Defendant‘s husband to transfer his wife. Defendant‘s husband  took the position that his wife should remain in the hospital for the remainder of her life. Plaintiff filed an action for an injunction to require Defendant to be removed from the hospital as a trespasser.

Synopsis of Rule of Law.

An injunction may be issued to enjoin a continuing trespass or a series of repeated trespasses if an action for damages would not be an adequate remedy.

Facts.

Defendant was a patient for a considerable amount of time at Sibley Memorial Hospital (the Hospital), which was operated by Plaintiff. The hospital is a private hospital. The hospital concluded that Defendant no longer needed acute care from the hospital and could be cared for by a nursing home. The hospital made a formal demand on June 2, 1967, to Defendant’s husband to transfer her out of the hospital. Defendant‘s husband took the position that Defendant should remain in the hospital until the end of her life. Defendant‘s husband was ready and willing to pay whatever the hospital would charge for the extended stay. Plaintiff sued Defendant, seeking an injunction ordering Defendant to leave the Hospital. Defendant moved to dismiss the lawsuit.

Issue.

Is an injunction to enjoin a continuing trespass or a series of repeated trespasses the proper remedy if an action for damages would not be an adequate remedy?

Held.

Yes.

Discussion.

An injunction may be issued to enjoin a continuing trespass or a series of repeated trespasses if an action for damages would not be an adequate remedy. A private hospital has a right to accept or decline any patient. It has a moral duty to reserve its accommodations for persons who actually need medical and hospital care and it would be a deviation from its purposes to act as a nursing home for aged persons who only need nursing, not medical, care do not need constant medical care but who need nursing care. There are homes for the aged, there are nursing homes and similar institutions. Here, Defendant has taken the position that she should remain in the hospital until the end of her life. This would be a diversion of the purpose of the facilities of the hospital. An action for damages would not be adequate here, because Defendant and her husband were willing to pay the charges for the length of Defendant‘s stay. Therefore, an injunction is an appropriate remedy. Accordingly, Defendant‘s motion to dismiss is denied.