Home › Case briefs › Civil Procedure

Lucy Webb Hayes National Training School for Deaconesses and Missionaries v. Geoghegan

United States District Court for the District of Columbia · Civil Procedure

Civil ProcedureInjunctionsEquityTrespassinjunctionequitycontinuing trespassrepeated trespass

Facts

The plaintiff operates Sibley Memorial Hospital, a private hospital, and defendant Ellen S. Geoghegan had been a patient there for a considerable time. The hospital concluded that she no longer needed hospital care and could be adequately cared for in a nursing home. On June 2, 1967, the hospital's president formally demanded of her husband, Thomas Geoghegan, that arrangements be made to transfer her from the hospital. The husband took the position that his wife should remain in the hospital for the rest of her life, and the hospital sought an injunction to compel her removal.

Issue

May a court of equity grant injunctive relief to remove a patient from a private hospital after the hospital has demanded her departure, on the theory that her continued presence constitutes a continuing trespass and damages would be inadequate? Do the possible availability of ejectment or forcible entry and detainer defeat equity jurisdiction?

Rule

A private hospital has the right to accept or decline any patient, and once it has demanded a patient's departure, the patient's continued presence becomes a trespass. Equity may enjoin a continuing trespass or repeated trespasses when an action for damages is not an adequate remedy, and the existence of other legal remedies does not negate equity's power where damages would be inadequate.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.

Maple Crest Medical Center, a privately operated hospital in Cleveland, determines that Nora Bell no longer needs hospital-level treatment and can be cared for at a skilled nursing facility. After the hospital administrator sends Nora's son a formal letter directing that she be transferred within five days, the family refuses and says she will remain there indefinitely while continuing to pay all charges.

If the hospital sues for an injunction requiring Nora's removal, what is the strongest basis for equitable relief under the governing rule?

Explanation. The majority rule is that a private hospital may accept or decline patients, and after it demands that a person leave, continued presence is treated as a trespass. Equity may enjoin a continuing trespass where damages at law are inadequate. The inadequacy is especially clear when the family is willing to pay, because a damages award would not solve the hospital's problem of continued occupation and diversion of facilities. (Derived from Lucy Webb Hayes National Training School for Deaconesses and Missionaries v. Geoghegan (n.d.).)