Doe v. Westfall Health Care Center, Inc

In Doe v. Westfall Health Care Center, Inc., (303 A.D.2d 102), the Appellate Division, Fourth Department declined to recognize the reasoning of its decision in Goldberg v. Plaza Nursing Home Comp, and recognized a cause of action under Public Health Law 2801-d. The court stated that ". . . we conclude that the clear intent of section 2801-d was to expand the existing remedies for conduct that, although constituting grievous and actionable violations of important rights, did not give rise to damages of sufficient monetary value to justify litigation." (Doe v. Westfall Health Care Center, Inc., id., at 109).