Reyes v. Glendale Mem’l Hosp. – June 2015 (Summary)

AGENCY

Reyes v. Glendale Mem’l Hosp., B255302 (Cal. Ct. App. June 26, 2015)

Following complications experienced by a patient after receiving care in the hospital’s ED, the patient sued the hospital on the grounds that the ED physician involved was the hospital’s agent. The trial court ruled in favor of the hospital’s summary judgment motion. On appeal, the California Court of Appeals reversed the trial court’s decision. The Appeals Court ruled that the hospital failed to refute the state law inference that the ED physician was the hospital’s agent, and that the hospital failed to show the patient knew of the ED physician’s independent status. The hospital had argued that it was not liable for the ED doctor’s care because the patient signed a form in her admission paperwork stating that “doctors caring for patients in the hospital are independent providers of medical care and are not employees or agents of the hospital.” In addition to making significant procedural mistakes in its summary judgment motion, the court found that the form was not enough to support the hospital’s motion because its mere existence was not sufficient to conclusively indicate that the patient should have known the physician was not the hospital’s agent.