Higgins v. R.I. Hosp.
Annotate this CasePlaintiff brought a patient to the hospital while working as an EMT/firefighter for the city. After he had delivered his patient but while he was still at the hospital, a nurse asked Plaintiff to assist her with a disorderly patient. While attempting to place a spit mask on the patient, Plaintiff was seriously and permanently injured. Plaintiff brought suit against Defendants, the hospital and the company that provided security to the hospital, alleging they were negligent when they failed to restrain the patient and that that failure caused Plaintiff's injuries. The superior court granted summary judgment in favor of Defendants, finding that Plaintiff's claim was barred by the firefighter's rule. At issue on appeal was whether the rule applies only when an injury arises from the same circumstances that originally brought the firefighter to the scene. The Supreme Court affirmed, holding that the firefighter's rule barred Plaintiff's claim where (1) Plaintiff was injured during the course of his employment as an on-duty EMT/firefighter; (2) Plaintiff reasonably could have anticipated that he would be injured in this manner; and (3) Defendants' negligence in improperly restraining the aggressive patients caused Plaintiff to be summoned to the scene where he was injured.
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