Apparent Agency Judgment in Favor of Hospital Final
Medical Litigation Alert
Healthcare Alert | 1 min read
Feb 7, 2014
In Steele v. Provena Hospitals, the jury returned a $1.5 million verdict against the emergency room physician and the hospital on an apparent agency theory. The mother of the adult patient directed the ambulance to the hospital and once there, the patient signed a consent which advised her that most of the physicians she would see were not hospital employees and agents. The patient also disclaimed any reliance on an agency or employment relationship between the doctors and the hospital in that form. The appellate court agreed that the sole evidence was the patient’s signed form in which she disclaimed reliance, and the mother’s testimony regarding reliance was not probative because the patient was an adult. It reversed the $1.5 million adverse verdict and ordered that judgment be entered in favor of the hospital. The Illinois Supreme Court has denied plaintiff leave to appeal. Steele v. Provena Hospitals, 2013 IL App (3d) 110374.
This is an update to a Representative Matter published in the December 17, 2013 issue of the Medical Litigation Newsletter.
Featured Insights

Consumer Crossroads: Where Financial Services and Litigation Intersect
May 14, 2026
Key Takeaways from the 2026 MBA Legal Issues and Regulatory Compliance Conference

In The News
May 13, 2026
Hinshaw Contributes Chapters to “Wrongful-Death and Survival Actions” IICLE Handbook

In The News
May 12, 2026
Hinshaw GC Steve Puiszis Discusses Protecting Attorney-Client Privilege in an AI Age

Event
May 12-13, 2026
Mitchel Chargo Speaks on the Rapidly Evolving Cannabis Industry

Consumer Crossroads: Where Financial Services and Litigation Intersect
May 11, 2026
Tennessee Reaches Settlement with Mariner in Multistate UDAAP Enforcement Action

Press Release
May 11, 2026
Ali Degan Elected to the Fellows of the American Bar Foundation

Press Release
May 11, 2026
John Weedon Re-Elected to the Jacksonville Bar Association’s Board of Governors in 2026

Press Release
May 7, 2026
Hinshaw Recognized as a 2026 BTI Associate Satisfaction A-Lister Firm

Press Release
May 7, 2026
Pedro Hernandez Recognized at the 2026 ALM Florida Legal Awards Gala




