Rhonda Baldwin, as of the Estate of Garrett O. Baldwin v. Central Iowa Hospital Corp., d/b/a Iowa Methodist Medical…

Summary

The court reversed the denial of summary judgment and remanded because the hospital was entitled to judgment on the negligent-retention, bystander-emotional-distress, and punitive-damages claims. It held that a negligent hiring, retention, or supervision claim is precluded when the employer admits vicarious liability for an employee acting within the scope of employment. It also held that Rhonda did not contemporaneously perceive the injury-producing medical event and that the evidence showed, at most, negligence rather than the willful or wanton conduct required for punitive damages.