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Guerrero v. Copper Queen Hospital

Citations: 23 Ariz. App. 172; 531 P.2d 548; 1975 Ariz. App. LEXIS 502Docket: No. 2 CA-CIV 1643

Court: Court of Appeals of Arizona; January 29, 1975; Arizona; State Appellate Court

Narrative Opinion Summary

In this case, the appellants brought a claim against a private hospital, challenging its refusal to provide emergency services in a critical situation. The core legal issue revolved around whether a private hospital can be held liable for denying services during an unmistakable emergency, particularly when there is an established practice of providing aid that the public relies upon. The appellants argued that the hospital's reputation as an emergency care provider created a reasonable expectation of service. The court determined that the case should proceed to trial, finding that the appellants adequately alleged reliance on the hospital's established practice in the First-Amended Complaint. The court explicitly stated that its decision does not compromise a private hospital's discretion in accepting patients, except where emergency services have been explicitly offered to the public. Moreover, the court clarified that it was not altering the common law in Arizona but recognizing the evolution of private hospital practices from traditional common law principles. Consequently, the appellants presented a viable claim for relief, and the motion for rehearing was denied, allowing the case to move forward to trial.

Legal Issues Addressed

Discretion of Private Hospitals in Accepting Patients

Application: The court clarified that its decision does not undermine a private hospital's discretion in accepting patients, except in cases where the hospital has explicitly offered emergency services to all.

Reasoning: The court rejected the notion that this decision undermines a private hospital's discretion in accepting patients, clarifying that its ruling is confined to instances where a hospital has explicitly offered emergency services to all individuals in need.

Liability of Private Hospitals in Emergency Situations

Application: The court ruled that a private hospital may be liable for refusing service in an unmistakable emergency, especially when the patient has relied on the hospital's established practice of providing aid.

Reasoning: Liability for a private hospital may arise from the refusal of service in an unmistakable emergency when the patient has relied on the hospital's established practice of providing aid.

Non-Alteration of Common Law in Arizona

Application: The court stated its intent not to alter Arizona's common law but acknowledged actions by private hospitals that deviate from traditional principles.

Reasoning: The court affirmed its intent not to alter the common law in Arizona but to acknowledge the actions of private hospitals that indicate a departure from traditional common law principles.

Reliance on Established Practice of Emergency Services

Application: The appellants sufficiently alleged reliance on the hospital's established practice of providing emergency services, which was recognized by the public.

Reasoning: Contrary to the appellees' assertions, the appellants adequately alleged reliance in their First-Amended Complaint, stating that the public recognized Copper Queen Hospital as an emergency care facility.