Grande v. Eisenhower Medical Center

Summary

The California Supreme Court affirmed that a nurse’s settlement with a staffing agency did not release her wage-and-hour claims against the hospital that used her services. The hospital could not invoke claim preclusion because it was not in privity with the staffing agency: their legal interests were not adequately aligned, and the hospital’s liability was not shown to be entirely derivative or covered by the indemnification theory asserted. The court also disapproved the contrary reasoning to the extent inconsistent with this decision.