Healthcare Staffing, Inc.v.Sadie Edwards Et Al.
Three cases arose from allegations that an employee of Healthcare Staffing abused mentally incapacitated patients at a behavioral-health facility. The patients’ guardians sued the staffing company for vicarious and direct negligence, negligent hiring and supervision, breach of contract, assault and battery, and fraud. On interlocutory appeal from cross-motions for summary judgment, the Court of Appeals of Georgia held that factual and legal issues required the tort claims to proceed, rejecting the company’s arguments based on the borrowed-servant doctrine and the direct-negligence claims. It nevertheless held that the patients were not intended third-party beneficiaries of the staffing contract with the facility. The court affirmed the denial of summary judgment on the tort claims, reversed it on the breach-of-contract claims, and remanded all three cases for further proceedings.
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