Response or Comment
Liability of Hospitals for the Negligence of their Physicians and Nurses.-This question was recently examined by the Supreme Court of Utah in the case of Gitzhoffen v. Sisters of Holy Cross Hospital Association, 88 Pac. Rep. 691 (Jan. 26, 1907), and the opinion filed may well serve as a basis for comment. The hospital association was sued for damages for injuries that plaintiff claimed to have sustained through the negligence of defendant's nurses.
Hutchins, Harry B. "Liability of Hospitals for the Negligence of Their Physicians and Nurses." Mich. L. Rev. 5 (1907): 552-9.