The benchmark case in the healthcare field, which has had a major impact on the liability of healthcare organizations, was decided in 1965 in Darling v. Charleston Community Memorial Hospital. The course her enunciated a "corporate negligence doctrine" under which hospitals have a duty to provide adequately trained medical and nursing staff. A hospital is responsible, in conjunction with its medical staff, for establishing policies and procedures for monitoring the quality of medicine practiced within the hospital.
The Darling case involved an 18-year-old college football player who was preparing for a career as a teacher and coach. The patient, a defensive halfback for his college football team, was injured during a ply. He was rushed to the emergency department of a small, accredited community hospital where the only physician on emergency duty that day was Dr. Alexander, a general practitioner. Alexander had not treated a major leg fracture for 3 years.
The physician examined the patient and ordered an X-ray that revealed that the tibia and the fibula of the right leg had been fractured. The physician reduced
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Under the circumstances in which the case reached the Illinois Supreme Court, it was held that the verdict against the hospital should be sustained if the evidence supported the verdict on any one or more of the 20 allegations of negligence. Allegations asserted that the hospital was negligent in its failure to (1) provide a sufficient number of trained nurses for bedside care for all patients at all times, in this case, nurses who were capable of recognizing the progressive gangrenous condition of the plaintiff's right leg, and (2) failure of its nurses to bring the patient's condition to the attention of the hospital administration and staff so that adequate consultation could be secured and the condition