Golek v. Saint Mary's Hospital, Inc.
Nothing in the record raised an inference that a fiduciary relationship existed between a hospital program director and a resident while the parties were negotiating the plaintiff's role in the surgical residency program and allegations that the director sometimes praised or criticized the plaintiff's performance and certified surgical residents' performance records did not suffice to establish anything other than a form of a student-teacher relationship. After being denied promotion to chief resident, Zygmunt Golek filed a multi-count complaint alleging, inter alia, that Saint Mary's Hospital, Inc. was in breach of its contractual obligations and the implied covenant of good faith and fair dealing. Golek alleged that the director of the hospital's surgery program, Stanley Dudrick, tortiously interfered with Golek's business expectations and breached his fiduciary duty to the plaintiff. Golek claimed that the organization that accredited the hospital's residency program, Accreditation Council for Graduate Medical Education, was liable to Golek as a third party beneficiary of ACGME's relationship with the hospital. The trial court, Eveleigh, J., granted Dudrick and ACGME's motions for summary judgment. At trial, the jury found for the hospital. Golek appealed challenging the propriety of the jury instructions, certain evidentiary rulings and the summary judgment rulings. The Appellate Court affirmed the judgment. The trial court properly accepted the jury's verdict upholding the hospital's decision not to promote Golek. The court did not err in contrasting the burden of proof in a civil case with the burden of proof in a criminal case in its jury instruction on the standard of proof in civil cases. This portion of the charge followed the text of the Superior Court's standard civil jury instructions. The trial court properly granted the summary judgment motions. The trial court found no actual loss supported the tortious interference claim against Dudrick. The plaintiff cited no authority for the proposition that an allegation of damage to his professional reputation sufficed to establish actual loss. Nothing in the record raised a factual inference that a fiduciary relationship existed between Dudrick and the plaintiff. The plaintiff's allegations did not suffice to establish anything other than a form of a student-teacher relationship.