Boring v. Conemaugh Memorial Hospital

TODD, J.,

dissenting:

¶ 1 Because I believe that under Welsh v. Bulger, 548 Pa. 504, 698 A.2d 581 (1997), an instruction on the issue of corporate negligence was appropriate in this case, I respectfully dissent.

¶2 In Welsh v. Bulger, an infant later died as the result of injuries negligently inflicted during delivery. Monitoring equipment indicated that the fetus was not receiving sufficient blood flow because the umbilical cord was compressed. Despite the indications that a cesarean section should be performed, the baby was delivered vaginally and suffered permanent injury. An expert report provided by the plaintiff indicated that the nurses should have known about the child’s deteriorating condition and that their failure to notify hospital authorities resulted in the child’s injuries.

¶ 3 Our Supreme Court held that, based on this report, the plaintiff had made a ;prima facie claim against the hospital for corporate negligence under Thompson v. Nason Hosp., 527 Pa. 330, 591 A.2d 703 (1991). The Court said:

In support of her claims for corporate negligence, [plaintiff] relies on the expert report of Dr. Warner. She first claims this report establishes that the hospital was corporately negligent for the failure to monitor and report the child’s condition, which is a violation of the duty to oversee all persons who practice medicine within its walls as to patient care, the third duty under Thompson. Read in the light most favorable to [plaintiff] as the nonmoving party, the report shows that Dr. Warner opined that the nurses breached the standard of care because they must have known that there was a problem with the delivery but failed to act on that knowledge. Dr. Warner concluded that this breach was a substantial factor in bringing about the harm to the deceased when he concluded that if the nurses had notified the hospital of the need for a cesarean section, then the injury would not have occurred. Thus, Dr. Warner’s report is sufficient to support a prima *863facie claim of corporate negligence for Nason Hospital’s failure to oversee all persons who practice medicine within its walls as to patient care.

Welsh, 548 Pa. at 514-15, 698 A.2d at 586 (footnote omitted). Thus, in Welsh, the breach by the nurses of the duty to monitor and report was alone sufficient to support a claim of corporate negligence.

¶ 4 In the instant case, the evidence at trial showed that the nursing staff failed to inform the surgeon that the patient recently had taken Naprosyn. Under Welsh, this breach of the standard of care by the staff (the failure to report the patient’s condition to the surgeon) supported a claim that the hospital violated its duty to oversee all persons who practice medicine within its walls as to patient care. The duty to oversee is one of the duties under Thompson, the breach of which supports a claim of corporate negligence. Welsh, 548 Pa. at 512-13, 698 A.2d at 585. Thus, I believe a corporate negligence instruction was appropriate on this basis.

¶ 5 Because the trial court erroneously failed to give a corporate negligence instruction, I would reverse and remand for a new trial. Accordingly, I respectfully dissent.