Kaltreider v. Lake Chelan Community Hospital

¶17 Elizabeth Kaltreider contends that because she had a special relationship with Lake Chelan Community Hospital, it had a duty to protect her from sexual misconduct by a nurse at the hospital, which is a foreseeable harm. The majority holds that the hospital did not owe her a duty of protection because she was not totally helpless and the nurse’s conduct was not foreseeable because the hospital had no knowledge of the nurse’s abusive proclivities. I interpret the relevant special relationship authority to hold that the scope of the protected party’s impairment establishes the scope of the…