New York Court of Appeals

Edwin Davis, Appellants v. South Nassau Communities Hospital, Respondents

December 16, 201526 N.Y.3d 563

Summary

The New York Court of Appeals held that a medical provider who administers medication that may impair a patient’s ability to drive has a duty to warn the patient for the benefit of foreseeable third‑party motorists, and therefore denied the defendants’ motions to dismiss. The court also denied plaintiffs’ request to amend the complaint to add a negligence claim, finding it lacked merit. Justice Stein dissented, arguing that no duty should extend to non‑patients.