Salih v. Lane

In this damage suit brought by a nurse anesthetist against a psychiatrist for injuries allegedly received during administration of electric shock therapy by the psychiatrist to a patient, the central issue is whether the plaintiffs common-law action is barred on the ground that her exclusive remedy is under the Virginia Workers’ Compensation Act (the Act).

In September 1990, appellee Margaret Ann Lane brought this action against appellant Hassan A. Salih, M.D., asserting that she was injured on September 14, 1988 in the Fairfax Hospital when electric current entered her body as the…