Clarke v. Bridgeport Hosp.,
No. CV00270869S (Conn. Super. Ct. June 15, 2001)

A resident filed suit against a hospital, alleging breach of contract and intentional infliction of emotional distress based on the hospital's failure to graduate her from its program after 36 months of training. The hospital moved for summary judgment, arguing that there was no guarantee of graduation in three years and that the residency contracts granted the hospital the absolute discretion to terminate or fail to renew the contract of any resident where quality concerns existed. The Superior Court of Connecticut agreed, ruling that the hospital's commitment was to ensure quality of care and that there was no obligation to advance a resident when questions of competence were present.