Williams v. Dimensions Health Corporation

In the early morning of May 3, 2014, Terence Williams (plaintiff) lost control of his car and crashed. The responding EMS personnel determined that, due to the severity of Williams’s injuries, he should be transported to Prince George’s Hospital Center, operated by Dimensions Health Corporation (defendant), the nearest level II trauma center. Level II trauma centers were specifically designated to treat patients with serious, life-threatening injuries on an emergency basis and were required to have surgeons on call. Upon Williams’s arrival, hospital staff intubated him. From that point forward, Williams was unconscious. Williams was then treated by Dr. Montague Blundon, the hospital’s on-call orthopedic surgeon. According to the hospital’s consent form, Dr. Blundon was neither an employee nor an agent of the hospital. However, because Williams was unconscious, he never reviewed or signed this form. Williams later brought suit against Dr. Blundon and the hospital, alleging that Dr. Blundon had acted negligently and that the hospital was vicariously liable for his conduct. At trial, Williams testified that he knew he was being transported to a trauma center and relied on the hospital, not a specific healthcare provider, for treatment. The jury returned a verdict in favor of Williams. However, the trial court granted the hospital’s motion for judgment notwithstanding the verdict, concluding that there was insufficient evidence to show that Williams believed Dr. Blundon was the hospital’s agent. The appellate court affirmed. Williams appealed.