Paulino v. QHG of Springdale, Inc.

Appellants, Theresa and Eddie Paulino, filed an action against Appellees, QHG of Springdale and NorthWest Arkansas Hospitals (collectively, NMC), for negligent credentialing and negligent retention after three surgeries left Mrs. Paulino unable to walk. The circuit court granted summary judgment in favor of NMC, concluding that, inter alia, the Medical Malpractice Act did not confer a cause of action for negligent credentialing, nor did a cause of action for negligent credentialing exist in Arkansas. The Supreme Court affirmed, holding that the circuit court did not err in determining that (1) the Medical Malpractice Act did not confer a cause of action for negligent credentialing; (2) there did not exist nor was it necessary to create a tort for negligent credentialing; and (3) because the nurse that monitored the surgeries was the employee of an independent contractor, NMC could not be held liable for negligent hiring, supervision, or retention of the nurse. View "Paulino v. QHG of Springdale, Inc." on Justia Law