Loeffel v. Dash
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The Supreme Court affirmed the judgment of the district court against Plaintiff on her negligent credentialing claim against the Board of Trustees of the Memorial Hospital of Carbon County (the Hospital), holding that the default judgment against Eric Dash, M.D. did not estop the Hospital from contesting his negligence.
Plaintiff filed a complaint alleging negligence against Dr. Dash and negligent credentialing and vicarious liability against the Hospital. When Dr. Dash failed to answer or otherwise defend the district court entered a default judgment against him. A two-phase jury trial was subsequently on the negligent credentialing claim against the Hospital, with the first phase trying the question of Dr. Dash's negligence. The jury returned a verdict finding no negligence. The district court then entered judgment in favor of the Hospital, finding that the negligence of Dr. Dash was a prerequisite to liability against the Hospital for negligent credentialing. The Supreme Court affirmed, holding that the district court (1) did not err when it found the default judgment against Dr. Dash was not binding on the Hospital on the basis of collateral estoppel or issue preclusion; and (2) did not abuse its discretion when it bifurcated the issue of Dr. Dash's negligence from the negligent credentialing claim against the Hospital.
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