7 Washington opinions name it 2 courts 1990–2025 4 in the last five years
The cases below were cited by Washington courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Pedroza v. Bryantgreen2 sentences2025In Pedroza v. Bryant, the Washington Supreme Court held that the corporate negligence doctrine imposed “a nondelegable duty” on hospitals to their patients. 101 Wn.2d 226, 229, 233 , 677 P.2d 166 (1984). 2025In Pedroza v. Bryant, the Washington Supreme Court held that the corporate negligence doctrine imposed “a nondelegable duty” on hospitals to their patients. 101 Wn.2d 226, 229, 233 , 677 P.2d 166 (1984). | 2 | 3 |
Rounds v. Nellcor Puritan Bennett, Inc.green1 sentence2023No. 1 of Grant County In a corporate negligence claim against a hospital, a plaintiff must show “a duty of care owed to plaintiff by the clinic, a breach of that duty, and proximate cause between the breach and plaintiff’s injury.” Douglas v. Freeman, 117 Wn.2d 242, 248 , 814 P.2d 1160 (1991). “‘A proximate cause of an injury is defined as a cause which, in a direct sequence, unbroken by any new, independent cause, produces the injury complained of and without which the injury would not have occurred.’” Rounds, 147 Wn. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Douglas v. Freeman
green
2 sentences2023No. 1 of Grant County In a corporate negligence claim against a hospital, a plaintiff must show “a duty of care owed to plaintiff by the clinic, a breach of that duty, and proximate cause between the breach and plaintiff’s injury.” Douglas v. Freeman, 117 Wn.2d 242, 248 , 814 P.2d 1160 (1991). “‘A proximate cause of an injury is defined as a cause which, in a direct sequence, unbroken by any new, independent cause, produces the injury complained of and without which the injury would not have occurred.’” Rounds, 147 Wn. 2023No. 1 of Grant County In a corporate negligence claim against a hospital, a plaintiff must show “a duty of care owed to plaintiff by the clinic, a breach of that duty, and proximate cause between the breach and plaintiff’s injury.” Douglas v. Freeman, 117 Wn.2d 242, 248 , 814 P.2d 1160 (1991). “‘A proximate cause of an injury is defined as a cause which, in a direct sequence, unbroken by any new, independent cause, produces the injury complained of and without which the injury would not have occurred.’” Rounds, 147 Wn. | 4 | 2019–2025 |
Alexander v. Gonser
green
2 sentences1991The trial court granted summary judgment in favor of the hospital on the corporate negligence claim and the Court of Appeals affirmed. 42 Wn. 1991The *263 trial court granted summary judgment in favor of the hospital on the corporate negligence claim and the Court of Appeals affirmed. 42 Wn. | 2 | 1990–1991 |
Taylor v. Intuitive Surgical, Inc.
green
2 sentences2024We “adopted the doctrine . . . to address negligence beyond that of the physician, to recognize the onus on the hospital itself for the competency of the hospital’s medical staff.” Taylor v. Intuitive Surgical, Inc., 187 Wn.2d 743, 756 , 389 P.3d 517 (2017) (citing Pedroza, 101 Wn.2d at 231-33 ). 2024We “adopted the doctrine . . . to address negligence beyond that of the physician, to recognize the onus on the hospital itself for the competency of the hospital’s medical staff.” Taylor v. Intuitive Surgical, Inc., 187 Wn.2d 743, 756 , 389 P.3d 517 (2017) (citing Pedroza, 101 Wn.2d at 231-33 ). | 1 | 2024–2024 |
Fabrique v. Choice Hotels International, Inc.
green
1 sentence2023App. at 162 (internal quotation marks omitted) (quoting Fabrique v. Choice Hotels Int’l, Inc., 144 Wn. | 1 | 2023–2023 |
Schoening v. Grays Harbor Community Hospital
green
2 sentences1991It is well settled that under the doctrine of corporate negligence, a hospital can be held liable for its own negligence in the absence of any negligence on the part of the treating physician. 23 As noted earlier, the corporate negligence theory is based on the proposition that a hospital owes an independent duty of care to its patients. 24 In Schoening v. Grays Harbor Comm'ty Hosp., 40 Wn. 1991It is well settled that under the doctrine of corporate negligence, a hospital can be held liable for its own negligence in the absence of any negligence on the part of the treating physician. [23] As noted earlier, the corporate negligence theory is based on the proposition that a hospital owes an independent duty of care to its patients. [24] In Schoening v. Grays Harbor Comm'ty Hosp., 40 Wn. | 1 | 1991–1991 |
Thompson v. Grays Harbor Community Hospital
green
1 sentence1990Thompson v. Grays Harbor Comm'ty Hosp., 36 Wn. | 1 | 1990–1990 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.