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lawsuitplaintiffnegligenceverdictduty of care
plaintiffnegligenceverdictduty of care

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Doe v. Saint Francis Hosp. and Medical Center, 309 Conn. 146, 72 A.3d 929

Facts

Beginning in 1964, Dr. George E. Reardon conducted a purported 'child growth study' at Saint Francis Hospital, which was actually a ruse to sexually exploit children. The plaintiff, Tim Doe #1, was recruited for the study at the age of eight, under the false pretense that he would be participating in legitimate medical research. Over several visits, Reardon sexually abused the plaintiff and took explicit photographs, actions that went unnoticed by the hospital despite its responsibility to supervise research conducted under its auspices. The plaintiff later filed a lawsuit against the hospital, claiming negligence in its supervision of Reardon.

Beginning in 1964, Dr. George E. Reardon conducted a purported 'child growth study' at Saint Francis Hospital, which was actually a ruse to sexually exploit children.

Issue

Whether the hospital could be held liable for negligence in failing to supervise Dr. Reardon without proof that it had actual or constructive knowledge of his propensity to sexually abuse children.

Whether the hospital could be held liable for negligence in failing to supervise Dr. Reardon without proof that it had actual or constructive knowledge of his propensity to sexually abuse children.

Rule

A hospital has a special duty of care to protect children in its custody, and it can be found liable for negligence if it fails to take reasonable precautions to prevent foreseeable harm, even without prior knowledge of a third party's criminal behavior.

A hospital has a special duty of care to protect children in its custody, and it can be found liable for negligence if it fails to take reasonable precautions to prevent foreseeable harm, even without prior knowledge of a third party's criminal behavior.

Analysis

The court determined that the jury could reasonably find that the hospital's failure to supervise Reardon's study created a foreseeable risk of harm to the children involved. The court rejected the hospital's argument that it needed to have prior knowledge of Reardon's criminal behavior to be held liable, emphasizing that the hospital's own bylaws and the standard of care required oversight of research activities. The jury was instructed to consider whether the hospital had a custodial relationship with the plaintiff and whether it had taken adequate precautions to protect him.

The court determined that the jury could reasonably find that the hospital's failure to supervise Reardon's study created a foreseeable risk of harm to the children involved.

Conclusion

The Supreme Court affirmed the jury's verdict in favor of the plaintiff, holding that the hospital could be liable for negligence without needing to prove that it had prior knowledge of the doctor's criminal actions.

The Supreme Court affirmed the jury's verdict in favor of the plaintiff, holding that the hospital could be liable for negligence without needing to prove that it had prior knowledge of the doctor's criminal actions.

Who won?

The plaintiff, Tim Doe #1, prevailed in the case because the jury found that the hospital had a duty to supervise the doctor and failed to take reasonable precautions to protect the children in its care.

The plaintiff, Tim Doe #1, prevailed in the case because the jury found that the hospital had a duty to supervise the doctor and failed to take reasonable precautions to protect the children in its care.

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