Valley Health Sys., LLC v. Murray, 544 P.3d 904

LaQuinta Whitley-Murray died at Centennial Hills Hospital during a sickle cell crisis after receiving Toradol; her estate sued the hospital operator, Valley Health System (Centennial), for negligence.
The estate claimed both medical negligence (related to medication administration) and breach of fiduciary duty (initially based on alleged understaffing, later argued as policy prioritizing profit over patient safety).
A jury awarded over $48 million in compensatory and punitive damages, finding Centennial liable under both negligence and breach of fiduciary duty theories.
The district court upheld the verdict, declined to apply Nevada's statutory damages cap for medical malpractice on the fiduciary duty claim, and also awarded attorney fees and costs.
Centennial appealed various aspects of the judgment, including the application of the damages cap, the existence of a hospital-patient fiduciary duty, and punitive damages.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does a hospital owe a fiduciary duty to patients in delivering medical care?	Hospitals are fiduciaries who must prioritize patient safety and can be held liable for breach.	No heightened fiduciary duty exists; duties are those of general care under medical malpractice law.	No fiduciary duty exists; hospital only owes standard care.
Does the statutory damages cap for professional negligence (NRS 41A) apply?	Damages cap does not apply if claims are based on breach of fiduciary duty, not professional negligence.	The claim sounds in medical malpractice, so statutory caps on damages must apply.	The cap applies; plaintiff’s claim is subject to NRS 41A limits.
Were punitive damages properly awarded based on breach of fiduciary duty?	Punitive damages were justified by policy and conduct shown at trial.	No basis for punitive damages absent actionable fiduciary duty.	Punitive damages award reversed; predicate claim fails as matter of law.
Was prejudgment interest improperly awarded on amounts representing future damages?	The issue was waived, or only a portion was future damages.	Prejudgment interest cannot cover future damages, only past losses.	Prejudgment interest vacated in part; can only be awarded on past damages.

Hoopes v. Hammargren, 102 Nev. 425 (Nev. 1986) (physician-patient relationship may involve fiduciary duties in certain circumstances)
Sherwood v. Danbury Hosp., 896 A.2d 777 (Conn. 2006) (courts reject finding of blanket hospital-patient fiduciary duty)
Moore v. Regents of the Univ. of Cal., 793 P.2d 479 (Cal. 1990) (hospital may be vicariously liable for physician’s breach, but does not itself owe fiduciary duty for treatment)
Wickliffe v. Sunrise Hosp., Inc., 101 Nev. 542 (Nev. 1985) (hospital owes patients duty to exercise reasonable skill and care)
Albios v. Horizon Cmtys., Inc., 122 Nev. 409 (Nev. 2006) (prejudgment interest cannot be awarded on future damages)