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Turner v. Memorial Medical Center

Illinois Supreme Court
233 Ill.2d 494, 911 N.E.2d 369 (2009)


Mark Turner (plaintiff) was a respirator therapist employed at Memorial Medical Center (Memorial) (defendant). The Joint Commission was an independent, nonprofit organization that established healthcare standards and evaluated organizations’ compliance with those standards. The Joint Commission performed an on-site survey of Memorial to determine whether Memorial would continue to receive Joint Commission accreditation. Memorial used a computer charting program that allowed medical professionals to electronically chart a patient’s file. The Joint Commission standard required that electronic charting be performed immediately after care was provided to a patient. Memorial required that such charting be performed merely at some point during the medical professional’s shift. Turner was asked to speak with a Joint Commission surveyor. During the meeting, Turner pointed out the discrepancy between the Joint Commission’s standard of immediate reporting and Memorial’s less-strict policy. Turner also told the surveyor that Memorial’s deviation from the Joint Commission’s policy jeopardized patient safety. Turner alleged that he was fired by Memorial as a result of these statements. Turner brought suit, arguing that Memorial retaliatorily discharged him for truthful statements, in violation of the public policy of patient safety by firing him. The trial court dismissed Turner’s complaint. The appellate court upheld the dismissal. The case was then brought before the state supreme court.

Rule of Law


Holding and Reasoning (Freeman, J.)

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