Supreme Court of Maryland
Williams v. Dimensions Health Corp.
July 28, 2022
Summary
The court held that sufficient evidence supported the jury’s finding that the surgeon who treated Williams at the hospital’s designated trauma center was the hospital’s apparent agent, making the hospital potentially vicariously liable for the surgeon’s negligence. The hospital’s trauma-center designation, the EMS decision to transport Williams there, Williams’s reliance on the hospital for treatment, and the absence of meaningful notice that the surgeon was an independent contractor supported the verdict. The judgment granting judgment notwithstanding the verdict was reversed, and the case was remanded for consideration of the hospital’s damages cross-appeal; the dissent would have affirmed because Williams did not subjectively believe that the surgeon was the hospital’s agent.