Payne v. Galen Hospital Corp.
Janis Payne, a hospital nurse, sustained a back injury while working for Galen Hospital and subsequently suffered a severe, permanently disabling reaction to Toradol, a medication prescribed for her injury and filled at the hospital's pharmacy. She received workers' compensation benefits for both the initial injury and the adverse drug reaction. Payne then sued Galen Hospital for negligence and gross negligence in filling the prescription. The Supreme Court of Texas affirmed the court of appeals' judgment, holding that Payne's Toradol reaction constituted a work-related injury under the Texas Workers' Compensation Act. Consequently, her common-law claims against the hospital were barred by the Act's exclusive-remedy provision, as the hospital was deemed to be acting in its capacity as an employer when providing the medication. The court rejected arguments regarding the scope of employment and the dual-capacity doctrine.