| Automatic Doors Get Closed on the Patient, Hospital Gets Pinched Hospitals Responsible If Doors, Equipment Malfunction on Helpless Patients |
Hospitals and their employees have a special duty to inspect doors and other equipment and maintain them in good operating order. Although mere happening of an accident does not establish that injured person has been a victim of negligence, malfunctioning equipment would give rise to inference of negligence. Add to this the human factor of hospital employees and you have grounds for a lawsuit.
Facts : In April, 1983, Vincent McDonald, while a patient at Aliquippa Hospital, was being transported by wheelchair from the x-ray department to his room. Because the leg rest on the wheelchair did not function properly, McDonald's right leg was protruding in a position parallel to the floor. When he was pushed through a set of automatic doors, the doors closed prematurely on and pinched his right foot. According to McDonald's testimony, the nurse who was pushing the wheelchair did not immediately cause the doors to be reopened but attempted to pull his foot through the closed doors, thereby causing the doors to close more tightly on his foot. As a consequence, McDonald sustained injuries for which he and his wife, Nancy, sought damages from the hospital.
They alleged that the doors had been improperly maintained and that the nurse had been negligent in failing to exercise due care for the safety of her patient. After the lower court had dismissed the suit, the appellate court reversed and reinstated the suit.
Court Decision: To establish a prima facie case of negligence against the hospital, plaintiffs were required to prove a duty of care on the part of the hospital and a breach thereof causing McDonald injury. A hospital has a duty to make its premises safe for patients, who are entitled to rely on the assumption that the hospital has exercised reasonable care for their safety while confined.
One who enters a private residence even for purposes connected with the owner's business, is entitled to expect only such preparation as a reasonable prudent householder makes for the reception of such visitors. On the other hand, one entering a store, theater, office building, or hotel, is entitled to expect that his host will make far greater preparation to secure the safety of his patrons than a householder will make for his social or even his business visitors.
Patients of hospitals are especially vulnerable to faulty doors and other equipment. Therefore, a hospital has a duty to inspect such equipment and maintain it in good operating order.
In the instant case, the husband plaintiff testified that the automatic doors in the hospital corridor were open as he approached in a wheelchair but that the doors unexpectedly closed on his right foot. The doors held his foot in a tight grip which was released only when the nurse manually forced the doors open. The failure of the doors to sense an object in their path and remain open until safe passage had been secured was a malfunction which would not ordinarily occur if the doors had been inspected and properly maintained.
Moreover, if the doors were not malfunctioning, then the nurse, who was an employee of the hospital and who had the husband-plaintiff in her charge, had a duty to be alert and to exercise care to move him through the doors without allowing them to close upon and do injury to the extended leg of her patient. Thus, even if the jury found that the automatic doors did not malfunction, it could nevertheless have inferred from the circumstances that a hospital employee had failed to exercise due care in moving the husband-appellant safely through the hospital doors. Where a relatively helpless patient is being moved through the corridors of a hospital by an employee of the hospital, a jury can infer that injuries caused to the patient by automatic doors were the result of hospital negligence.
In addition, the testimony was that the nurse, when she saw what happened, momentarily panicked and attempted to pull the husband-plaintiff through the door instead of acting immediately to release the doors. This, according to the testimony, caused the doors to close more tightly upon plaintiff's foot. From this testimony, a jury could also find that this specific, momentary carelessness by the nurse, an employee of the hospital, had contributed causally to the injury sustained by the husband-plaintiff.
For these reasons, we are constrained to conclude that the entry of a compulsory non-suit was improper.
McDonald v. Aliquippa Hospital, 606 A.2d 1218 (Pa.Super. 1992)