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Danner v. Holy Cross Hospital

Citations: 474 N.W.2d 124; 189 Mich. App. 397Docket: Docket 116922

Court: Michigan Court of Appeals; May 20, 1991; Michigan; State Appellate Court

Narrative Opinion Summary

Plaintiff Danner appealed the Wayne Circuit Court's dismissal of his negligence claim against Holy Cross Hospital, which was dismissed under the Malpractice Arbitration Act (MAA). The court affirmed the dismissal, ruling that Danner's claim, despite being framed as corporate negligence for the hospital's failure to assess a doctor's competency, actually constituted a medical malpractice claim. The court referenced the precedent set in Bronson v Sisters of Mercy Health Corp, which established that claims related to the provision of medical care, including supervision of medical staff, fall under medical malpractice. The court emphasized that the essence of a malpractice claim is whether negligence occurred within a professional medical relationship. Since Danner's complaint involved substandard treatment by a physician at the hospital, it was deemed a medical malpractice action subject to the arbitration agreement. Consequently, the trial court's decision to dismiss was upheld.

Legal Issues Addressed

Application of Precedent in Malpractice Cases

Application: The court relied on the precedent established in Bronson v Sisters of Mercy Health Corp to classify the plaintiff's claim as medical malpractice since it related to the supervision and competency of medical staff.

Reasoning: The court referenced the precedent set in Bronson v Sisters of Mercy Health Corp, which established that claims related to the provision of medical care, including supervision of medical staff, fall under medical malpractice.

Classification of Claims under Medical Malpractice

Application: The court determined that Danner's claim, although framed as corporate negligence, was actually a medical malpractice claim because it involved the assessment of a doctor's competency, which is integral to medical care.

Reasoning: The court affirmed the dismissal, ruling that Danner's claim, despite being framed as corporate negligence for the hospital's failure to assess a doctor's competency, actually constituted a medical malpractice claim.

Enforcement of Arbitration Agreements in Malpractice Cases

Application: Danner's claim, being classified as a medical malpractice action, was subject to the arbitration agreement, leading to the trial court's dismissal being upheld.

Reasoning: Since Danner's complaint involved substandard treatment by a physician at the hospital, it was deemed a medical malpractice action subject to the arbitration agreement.

Essence of a Malpractice Claim

Application: The court emphasized that the core of a malpractice claim is the occurrence of negligence within a professional medical relationship, which applied to Danner's allegations of substandard treatment.

Reasoning: The court emphasized that the essence of a malpractice claim is whether negligence occurred within a professional medical relationship.