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Salerno v. Huntington Hospital Dolan Family Health Center, Inc.

Citations: 98 A.D.3d 730; 950 N.Y.S.2d 202

Court: Appellate Division of the Supreme Court of the State of New York; August 29, 2012; New York; State Appellate Court

Narrative Opinion Summary

In a medical malpractice case, the defendant, a hospital, appealed an order denying its motion for summary judgment, claiming the action was time-barred. The decedent, who was misdiagnosed at the hospital in December 2002, filed the lawsuit in July 2006, alleging malpractice. The defendant argued the statute of limitations had expired, while the decedent claimed the continuous treatment doctrine tolled the limitations period. The court identified issues of fact concerning whether treatment at the hospital's affiliated center was continuous and relevant to the initial misdiagnosis and whether the center operated as an agent of the hospital. An affidavit supported the claim that the center was a hospital subsidiary, sharing staff and systems. Due to these unresolved factual issues, the court affirmed the denial of the defendant's motion for summary judgment, allowing the case to proceed to trial.

Legal Issues Addressed

Agency and Subsidiary Relationships in Medical Malpractice

Application: The court considered whether the Dolan Center staff acted as agents of the hospital, affecting liability and the application of the continuous treatment doctrine.

Reasoning: An affidavit indicated that the Dolan Center was a subsidiary of the hospital, with shared staff and systems.

Continuous Treatment Doctrine

Application: The decedent invoked the continuous treatment doctrine, asserting that ongoing treatment related to the initial misdiagnosis tolled the statute of limitations.

Reasoning: The decedent countered with the continuous treatment doctrine, claiming the treatment received was related to her initial condition and therefore tolled the statute of limitations.

Statute of Limitations in Medical Malpractice Claims

Application: The defendant argued that the malpractice claim was time-barred as it was filed beyond the 2.5-year period stipulated by law.

Reasoning: The defendant argued that the statute of limitations for medical malpractice claims (2.5 years) had expired.

Summary Judgment Standards

Application: The court determined that a genuine issue of material fact existed regarding the continuity and relevance of treatment provided, justifying the denial of summary judgment.

Reasoning: The court found that a triable issue of fact existed regarding whether the treatment at the Dolan Center was continuous and relevant to the original condition.