Sandra M. v. St. Luke's Roosevelt Hospital Center
The plaintiffs, Sandra M. and her husband, appealed a Supreme Court order granting summary judgment to St. Luke's Roosevelt Hospital Center, dismissing their complaint. Sandra M. was allegedly sexually assaulted by a nursing assistant, Ricardo Cortez, supplied by United Staffing System, Inc., while on suicide watch at the Hospital. The plaintiffs sued the Hospital, United, and Cortez, alleging the Hospital was negligent in its suicide watch policies and its failure to independently evaluate staff provided by United. The Appellate Division dismissed the appeal from the intermediate order and affirmed the judgment dismissing the complaint against the Hospital. The court found the Hospital was not vicariously liable for Cortez's personal tortious acts and had no duty to independently screen employees supplied by United, as it had no prior knowledge of Cortez's propensity for misconduct.