Third Party Accidents: Extending Fault in Motor Vehicle Accidents To Responsible Third Parties

What happens when an employee, who is required to work excessive hours without sufficient sleep, leaves work and later injures someone in a CT car accident? Can the employer be held liable in such a situation?

A decision was recently made in such a case involving a resident physician employed by Yale New Haven Hospital.  In Julie Penry v. Yale New Haven Hospital, the doctor, after leaving work and hitting another car, admitted that the accident was her fault due to the fact that she had fallen asleep while operating her motor vehicle.  Interestingly, the Plaintiff did not allege that the doctor was operating her vehicle within the scope of her employment with Yale New Haven Hospital.

The Plaintiff filed suit against Yale New Haven Hospital claiming the hospital was negligent in permitting the doctor to work excessive hours without sleep prior to the accident and also alleged that the hospital personnel allowed her to leave the hospital when it was not safe for her to do so.

In this case, the doctor had just finished working a twelve hour shift.  Further, the hospital work schedule for interns requires them to work four, twelve hour shifts in a row.  According to the doctor, this was her third shift in the four shift rotation.

The Plaintiff claimed that the hospital was negligent and that its negligence was the proximate cause of the Plaintiff's injuries.  The Defendant argued that it could not have foreseen that the injury to the Plaintiff was a likely result of its actions and that any negligence on the part of the hospital could not be the proximate cause of the accident.

The Court found that Yale New Haven Hospital requires interns and residents to work a twelve hour shift and to treat patients in need of medical care.  It recognized that sleep deprivation may affect the quality of medical care and has adopted a policy concerning the number of hours to be worked.

The Court reasoned that, based upon the facts presented to it, the number of hours worked by resident physicians has been discussed and debated.  Literature has been devoted to the subject and the effects of prolonged sleep deprivation are known to hospital and medical personnel.

Based upon the foregoing, the Court found that a duty of care existed on the part of the hospital to the Plaintiff and that it cannot be said that any negligence on the part of Yale New Haven Hospital was not a substantial factor in causing the accident and resulting injuries to the Plaintiff.

Accordingly, the Motion for Summary Judgment filed by the hospital was denied.