Rodriquez v. City & County of Denver

In Rodriquez v. City & County of Denver, 702 P.2d 1349 (Colo. App. 1984), a division of this court followed the decision in Moon, holding that a hospital could not be held liable under the doctrine of respondeat superior for negligence of individual treating physicians engaged in a multi-year postgraduate residency program designed to perfect their skills in a particular specialty. Despite the fact that the physicians may not have been licensed to practice as private physicians in Colorado, the Rodriquez court concluded that the hospital lacked authority to control or dictate the professional judgment independently exercised by the physicians relative to diagnosis and treatment.