Choe v. Axelrod

141 A.D.2d 235, 534 N.Y.S.2d 739, 1988 N.Y. App. Div. LEXIS 10934
CourtAppellate Division of the Supreme Court of the State of New York
DecidedNovember 3, 1988
StatusPublished
Cited by9 cases

This text of 141 A.D.2d 235 (Choe v. Axelrod) is published on Counsel Stack Legal Research, covering Appellate Division of the Supreme Court of the State of New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Choe v. Axelrod, 141 A.D.2d 235, 534 N.Y.S.2d 739, 1988 N.Y. App. Div. LEXIS 10934 (N.Y. Ct. App. 1988).

Opinion

OPINION OF THE COURT

Weiss, J. P.

An anonymous phone call to the State Department of Health precipitated an investigation of two alleged incidents of patient neglect at the New Vanderbilt Nursing Home on Staten Island involving a patient and Danny O’Brien, an orderly. The first incident occurred on December 15, 1982 when O’Brien allegedly left the patient unattended in the shower and the latter sprayed himself with hot water sustaining second degree burns on his forehead. A similar incident ostensibly occurred on May 19, 1983 but no one was injured. Janette Favia, an investigator for the Department, concluded [237]*237that both incidents constituted patient neglect and that petitioner, the Director of Nursing at the facility during this period, failed to report the incidents in violation of Public Health Law § 2803-d and 10 NYCRR part 81. Following a hearing, an Administrative Law Judge (hereinafter ALJ) sustained the charge relating to the December 15, 1982 incident but dismissed the May 19, 1983 charge as unsubstantiated; a fine of $150 was recommended. Respondent Commissioner of Health adopted the ALJ’s report, precipitating this CPLR article 78 proceeding to annul the administrative determination.

Petitioner’s initial contention is that the Department failed to establish a prima facie case of patient neglect so as to trigger the pertinent reporting requirements. Public Health Law § 2803-d requires the filing of a report with the Department when a person has reasonable cause to believe that a resident of a residential health care facility has been abused, mistreated or neglected (see, 10 NYCRR 81.2 [a]; 81.1 [c]). The evidence at the hearing included Favia’s written report and the testimony of Vilma Osborne, a supervisor in the Patient Care Investigations Unit of the Department, who opined, on the basis of the Favia report, that the December 15, 1982 incident should have been reported to the Department.

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Bluebook (online)
141 A.D.2d 235, 534 N.Y.S.2d 739, 1988 N.Y. App. Div. LEXIS 10934, Counsel Stack Legal Research, https://law.counselstack.com/opinion/choe-v-axelrod-nyappdiv-1988.