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 owes a duty to warn the patient, thereby extending liability to third‑party motorists injured as a result, and affirmed the lower court’s denial of the defendants’ motions to dismiss while rejecting plaintiffs’ request to amend the complaint to add a negligence claim. Justice Stein dissented, arguing that no such duty to non‑patients should be recognized.