Manning v. United Med. Corp. of New Orleans

MALPRACTICE – CORPORATE NEGLIGENCE

Manning v. United Med. Corp. of New
Orleans, No. 2004-CA-0035 (La. Ct. App. April 20, 2005)

A patient brought an action against a hospital’s officers
and directors ("directors")
alleging negligent credentialing of a physician, and sought to hold the directors
personally liable. The trial court dismissed the action, and the patient appealed,
arguing that the directors owed a personal duty to the patient.

The Louisiana Court of Appeals stated that if the directors delegated their
responsibility with due care, no personal duty or liability exists. The appeals
court then found that the responsibility for credentialing decisions was properly
delegated to the credentialing committee, and affirmed the dismissal of the
action.