Corbett v. ManorCare of Am., Inc
In Corbett v. ManorCare of Am., Inc., 213 Ariz. 618, 629, P 36, 146 P.3d 1027, 1038 (App. 2006), the Court held that it is not necessary that there be a "direct caregiver-patient relationship for liability to arise under APSA." Id. at 628, P 33, 146 P.3d at 1037.
As a result, we found that a director of nursing at a care facility could be held liable under the statute. Id. at 629, P 38, 146 P.3d at 1038.
In part, the duties of the director of nursing in Corbett included "managing the daily operations of the department of nursing services at the Tucson facility, which included overseeing patient care and staff education, 'helping to direct . . . the clinical aspects of resident care,' managing the staff, and ensuring that federal and state regulations were followed." Id.
In contrast, Corbett held that employees who had never met, spoken to, or had any personal contact with, and had no personal knowledge of the decedent's condition, her care, or her treatment did not "provide care" under the statute. Id. at P 37.