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Johnson v. Jamaica Hospital

(1984)

New York Court of Appeals - 62 N.Y.2d 523

tl;dr:

Plaintiffs' baby was abducted due to hospital's negligence and returned months later; the Court holds that Plaintiffs cannot recover for their emotional distress because they were not in the zone of danger.

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Facts & HoldingJohnson v. Jamaica Hospital case brief facts & holding

Facts:A baby was abducted from Defendant hospital due to Defendant's...

Holding:The New York Court of Appeals affirmed. In its analysis,...

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Johnson v. Jamaica Hospital | Case Brief DeepDive
Majority opinion, author: Kaye, J.
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The New York Court of Appeals held that a hospital does not owe a direct duty to parents of a hospitalized child to care properly for their child, and therefore, the parents cannot recover damages for mental distress caused by the child's injury. Liability is based on exceptional circumstances where the hospital's breach of care caused direct injury to the patient, resulting in emotional injury to the patient's relatives. Recovery for mental distress by parents has been allowed in cases where a hospital interferes with the parents' custody of their child. The contractual relationship between the plaintiffs and the defendant hospital does not provide a basis for recovery for mental distress, but the hospital has a duty of reasonable care towards the parents. Recovery for mental distress is appropriate where there is a guarantee that the claim is not spurious and the mental distress is undoubtedly real and serious, regardless of whether the defendant's act was negligent or intentional.

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Johnson v. Jamaica Hospital

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