Thompson v. Nason Hospital

Brief Fact Summary. Nason Hospital (Defendant) was held liable for negligent medical services.

Synopsis of Rule of Law. In order to charge a hospital with negligence, it must be shown that the hospital had actual or constructive knowledge of the defect or procedures that caused the harm, and the negligence of the hospital must have been a significant factor in bringing about the harm.

Facts. Following an automobile accident, Mrs. Thompson (Plaintiff) was admitted to the hospital where she remained in intensive care for three days.  On the fourth day, she developed complete paralysis of the left side, which she never recovered from.  Plaintiff sued Defendant, claiming that her injuries were the direct and proximate result of Defendant’s negligence acting through its agents, servants, and employees who failed to sufficiently examine and treat her.  The court adopted a theory of corporate liability with respect to Defendant and found it liable.  Defendant appealed.

Issue. In order to charge a hospital with negligence, must it be shown that the hospital had actual or constructive knowledge of the defect or procedures that caused the harm, and the negligence of the hospital must have been a significant factor in bringing about the harm?

Held. (Zappala, J.)  Yes.  In order to charge a hospital with negligence, it must be shown that the hospital had actual or constructive knowledge of the defect or procedures that caused the harm, and the negligence of the hospital must have been a significant factor in bringing about the harm.  There was a material issue of fact regarding Nason Hospital’s (Defendant) duty to monitor the medical services Plaintiff was provided.  There was a failure to report changes in the condition of the patient that was not in accord with standard medical practice.  Affirmed.

Discussion. In this case, the court adopted the doctrine of corporate negligence or corporate liability as a theory of hospital liability.  A hospital is liable if it fails to uphold the proper standard of care.  This type of corporate liability is a new trend.