Estate of Longsoldier v. Blaine CountyAnnotate this Case
The Supreme Court reversed the district court's entry of summary judgment in favor of the Estate of Allen J. Longsoldier, Jr. declaring that Hill County was vicariously liable for the negligence of the Northern Montana Hospital (NMH) under the non-delegable duty doctrine, holding that Hill County could not be held vicariously liable for NMH's medical negligence.
Longsoldier, who was being detained at the Hill County Detention Center, died at NMH due to the effect of alcohol withdrawal syndrome. Longsoldier's Estate filed this negligence action against Hill County, arguing that it had a non-delegable duty to provide Longsoldier with reasonable medical care and was therefore vicariously liable for NMH's medical negligence. The district court concluded that Hill County was vicariously liable for NMH's actions on the ground that public policy dictated the creation of a non-delegable duty. The Supreme Court reversed, holding that under the proper tests, Hill County was not vicariously liable for NMH's medical negligence.