Saint Joseph Healthcare, Inc. v. ThomasAnnotate this Case
The executor of the estate of James Gray and Gray’s statutory survivors (collectively, the Estate) filed a complaint against Saint Joseph Hospital alleging that the Hospital had engaged in medical negligence in its treatment of Gray following two visits to the Hospital’s emergency room. The jury returned a verdict in favor of the Estate. The circuit court awarded $1.45 million in punitive damages, and the court of appeals affirmed. The Supreme Court affirmed, holding (1) the evidence was sufficient to support an award of punitive damages; (2) the evidence established that the Hospital ratified its staff’s misconduct so as to authorize an award of punitive damages against it; (3) the jury was properly instructed regarding the Hospital’s liability based upon tortious conduct of the independent contractor physicians engaged to provide emergency room services; (4) the punitive damage award did not violate the Due Process provisions of the Fourteenth Amendment; and (5) the trial court did not abuse its discretion by not dismissing an alleged sleeping juror.