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Appeals Court Affirms Summary Judgment in Favor of AMN Healthcare (02/15/12)

In the case of Meehan v. AMN Healthcare Inc., summary judgment was granted by a trial court in favor of AMN Healthcare, Christina Bergfield, and Bethesda Hospital Inc. Daniel and Mary Meehan appealed the trial court’s decision, and the Court of Appeals of Ohio, First District, affirmed in part, reversed in part, and remanded the case for additional proceedings.

The case centered around bedsores Daniel Meehan incurred while a patient at Bethesda Hospital; Bergfield was Meehan’s nurse and was placed at Bethesda by AMN. The Meehans argued that the trial court should not have entered judgment in favor of the defendants because Bergfield was Meehan’s nurse when the bedsores arose, and because expert testimony found that a breach in the nursing standard of care resulted in Meehan’s injury.

However, the Court of Appeals disagreed, saying the trial court correctly entered summary judgment in favor of Bergfield. Likewise, the Court of Appeals found that because the trial court correctly entered summary judgment in favor of Bergfield, and because AMN’s only connection to the case was that Bergfield allegedly was on assignment from AMN, summary judgment was correctly entered in favor of AMN. The case against Bethesda, however, has been remanded for additional proceedings.