Conners v. Northeast Hosp. Corp.,
No. SCJ-08802 (Mass. May 29, 2003)

A woman sued a hospital, an employee and two subcontractors after she fell on ice and snow in a hospital parking lot. The lower court found no liability against the employee and the two subcontractors, but did find liability on the part of the hospital. The court initially awarded damages of $183,000, but then reduced it to $20,000 on a motion by the hospital to amend the award pursuant to state statute which limits liability of charitable corporations.

On appeal, the plaintiff argued that the hospital should not be considered a "charity" because of the corporate reorganization of the hospital which included for-profit entities, and that maintenance of the parking lot, specifically snow removal, did not advance "charitable purposes," necessary for the statute to apply. The Massachusetts Supreme Court disagreed, holding that the hospital met the definition of charity because the dominant purpose of the hospital's work was providing a benefit for the public good. In addition, the court held that snow removal directly accomplished its charitable purpose, thus rendering the damage cap applicable.