Lucy Webb Hayes National Training School v. Geoghegan
281 F.Supp. 116 (1967)
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Rule of Law:
A private hospital may obtain an injunction to remove a patient who no longer requires hospital care and refuses to leave, as the patient's continued presence constitutes a continuing trespass for which the legal remedy of damages is inadequate.
Facts:
- Ellen S. Geoghegan was a patient for a considerable time at Sibley Memorial Hospital, a private institution.
- The hospital's medical staff determined that Geoghegan no longer required acute hospital care and could be adequately cared for in a nursing home.
- On June 2, 1967, the president of the hospital formally demanded that Thomas Geoghegan, Ellen's husband, make arrangements for his wife's transfer out of the hospital.
- The Geoghegans refused to remove Ellen from the hospital.
- Thomas Geoghegan indicated his desire for his wife to remain in the hospital for the remainder of her life.
- Thomas Geoghegan was able and willing to pay any charges the hospital would assess for his wife's continued occupancy.
Procedural Posture:
- Sibley Memorial Hospital (plaintiff) filed an action in the U.S. District Court seeking an injunction to require the removal of Ellen S. Geoghegan.
- The defendants, Ellen and Thomas Geoghegan, filed a motion to dismiss the plaintiff's action.
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Issue:
Is an injunction a proper equitable remedy for a private hospital to compel the removal of a patient who has been formally discharged but refuses to leave, thereby becoming a trespasser?
Opinions:
Majority - Holtzoff, District Judge
Yes, an injunction is a proper remedy. Once the hospital demanded the patient's removal, her legal status changed to that of a trespasser. A private hospital has the right to manage its accommodations and a moral duty to reserve them for patients who actually need hospital-level care, rather than acting as a nursing home. The patient's continued, unwanted presence is a continuing trespass. Equity has long recognized its power to enjoin a continuing trespass where the remedy at law is inadequate. Here, an action for damages would be an inadequate remedy because the patient's husband is willing to pay, which would not solve the underlying problem of the hospital's facilities being diverted from their intended purpose of caring for the acutely ill. The availability of other, more cumbersome legal actions like ejectment does not diminish the court's power to grant equitable relief.
Analysis:
This case clarifies that the traditional property law concept of a continuing trespass can be applied to the unique context of a hospital-patient relationship. It establishes that a patient's license to be on hospital property is revoked upon discharge, and refusal to leave constitutes a trespass. The decision is significant for affirming that the inadequacy of a legal remedy, a prerequisite for an injunction, is not solely a question of monetary recovery but also considers whether the remedy can abate the actual harm—in this case, the misallocation of vital healthcare resources. This precedent provides healthcare facilities with a powerful legal tool to manage patient flow and ensure their facilities are used for their intended purpose.
