Diaz v. New York Downtown Hospital
The dissenting opinion by Mazzarelli, J., joined by Saxe, J., argues against granting summary judgment to New York Downtown Hospital in a case involving alleged sexual misconduct during a vaginal sonogram. The dissent asserts that the plaintiff's expert radiologist provided sufficient evidence, based on 1995 American College of Radiology (ACR) and American Institute of Ultrasound in Medicine (AIUM) guidelines, indicating the hospital's deviation from the standard of care by not ensuring a female chaperone was present. Mazzarelli, J., contends that these national guidelines explicitly recognized the risk of such misconduct and constitute generally accepted industry standards. The dissent also distinguishes the present case from precedents cited by the majority, emphasizing the probative value of expert testimony regarding custom and practice. Furthermore, it challenges the majority's unforeseeability argument, concluding that the guidelines delineated a foreseeable risk, thus necessitating the denial of the defendant's motion for summary dismissal.