Coats v. Sampson County Memorial Hospital, Inc.
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Coats v. Sampson County Memorial Hospital, Inc. was a case before the North Carolina Supreme Court in 1965 concerning the definition of public body.
Important precedents
This case established two important precedents:
- That private agencies who serve a public function are considered agents of the public bodies who would normally hold that responsibility.
- Operating hospitals is in fact a public, governmental function and can render a semi-private county hospital a public body.[1]
Background
- This case arose from a liability litigation against Sampson County Memorial Hospital. The core contention of the case was whether Sampson County Memorial Hospital was considered an agent of the county and whether or not the county was liable for the actions of the hospital. If the hospital was an agent of the county, then the trial would need relocated to Sampson County.[1]
Ruling of the court
The Supreme Court determined that the Hospital did in fact fall under the definition of public agency and was thus under the jurisdiction of the legal process relating to municipalities. The court determined that the functions of maintaining and operating a hos;ital were in fact governmental functions. The court went on to determine that the county had delegated those functions to the operating managers of the hospital. This rendered the hospital an agent of the county.[1]
Associated cases
See also
External links
Footnotes