Ruff v. York Hospital

Appellate courts will refer to trial courts’ decisions regarding factual issues.

The case involves a wrongful death and survival action against a hospital that alleged corporate liability, vicarious liability and negligence against a cardiologist.

The Court of Common Pleas of York County dismissed the claim against the cardiologist with prejudice, and the jury returned a verdict in favor of the hospital. There were numerous pretrial motions, including motions for summary judgment, motions for discovery and motions in limine. Trial commenced solely on the corporate negligence claim against the defendant hospital. The jury returned a defense verdict in favor of the hospital.

The plaintiff then filed post-trial motions, requesting a new trial and judgment notwithstanding the verdict, which the trial court denied.

On appeal, the plaintiff asserted that she is entitled to a new trial and/or JNOV on her corporate negligence claim because the evidence established that: (1) the hospital delegated its non-delegable duties; (2) the hospital’s operating rules did not establish that it accepted its responsibility to ensure the patient’s safety; and (3) the hospital failed to supervise the physicians responsible for the patient’s care.

On appeal, the court explained that because the trial judge has the opportunity to hear and see the evidence presented, an appellate court will give the gravest consideration to the findings and reasons advanced by the trial judge when reviewing a trial court’s determination that the verdict is against the weight of the evidence. The court held that the evidence supported the jury’s verdict that the hospital was not corporately negligent, and the evidence indicated that the hospital met its duty to oversee the practitioners within hospital.

This case is significant in that it illustrates that appellate courts will defer to the trial court’s decisions regarding factual issues.


Case Law Alerts, 3rd Quarter, July 2021 is prepared by Marshall Dennehey Warner Coleman & Goggin to provide information on recent developments of interest to our readers. This publication is not intended to provide legal advice for a specific situation or to create an attorney-client relationship. Copyright © 2021 Marshall Dennehey Warner Coleman & Goggin, all rights reserved. This article may not be reprinted without the express written permission of our firm.