Rodgers v. St. Mary’s Hospital
Supreme Court of Illinois
597 N.E.2d 616 (1992)
- Written by DeAnna Swearingen, LLM
Facts
In May 1986, Rodgers (plaintiff) sued his wife’s obstetricians, radiologists, and St. Mary’s Hospital (the hospital) (defendant), alleging their medical malpractice caused her wrongful death. Rodgers claimed his wife’s condition was apparent in an X-ray, but the X-ray was lost before trial. Summary judgment was granted to the hospital. After trial, in June 1988, the jury awarded $1.2 million in damages from the obstetricians, but concluded the radiologists were not liable. The obstetricians appealed but later settled for $800,000. While that case had been pending, Rodgers sued the hospital in a separate lawsuit in September 1987 for its failure to preserve his wife’s X-rays for five years, as required by state law. Rodgers argued the hospital’s breach of its statutory duty resulted in loss of evidence essential to his claim against the radiologists. Rodgers contended that had the radiologists been found liable, the original $1.2 million verdict would never have been appealed. Thus, Rodgers sought the $400,000 difference between that and the settlement. The trial court dismissed. Rodgers appealed, and the appellate court reversed, holding that Rodgers’s statutory claim had not been waived or barred by res judicata. The hospital appealed.
Rule of Law
Issue
Holding and Reasoning (Miller, C.J.)
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