Smith v. St. Joseph's Hospital, Inc.
Court: Appellate Division of the Supreme Court of the State of New York; December 5, 1994; New York; State Appellate Court
An order was issued by the Supreme Court of Bronx County (Justice Anita Florio) on April 16, 1993, granting partial summary judgment to the plaintiff against defendants St. Joseph's Hospital, Joel Lee Axler, and Conrado Lota for negligence, medical malpractice, and failure to notify the plaintiff of her husband's hospitalization. The court denied the plaintiff's motion for summary judgment regarding assault, battery, and civil rights violations, ultimately granting the defendants summary judgment on those claims and dismissing them. However, the court modified this decision by reinstating the causes of action for assault, battery, unlawful imprisonment, and civil rights violations, indicating that summary judgment was inappropriate for these claims. The case involved a significant misidentification of the decedent as another patient named "John Smith," which led to his involuntary commitment to a psychiatric ward and a failure to notify his wife of his hospitalization and subsequent death. The court noted that the decedent had provided correct personal information upon admission, highlighting the negligence of the hospital staff. The failure to notify the wife constituted a valid cause of action. Questions of fact remained regarding the actions of doctors Goldman and Larson, particularly whether they acted appropriately by not verifying the patient's identity based on prior physician actions. Additionally, the court determined that it was unclear if the decedent was appropriately involuntarily committed, necessitating further examination of whether exigent circumstances existed and whether medication was administered involuntarily. The dissenting opinion by Justice Kupferman supported affirming the order based on Justice Florio's reasoning.