Topete v. Sutter Health Sacramento Sierra Region (unpublished, 3rd Civ. C074716): Plaintiff brought a medical malpractice action against GMSR’s client, Sutter Health Sacramento Sierra Region, and several individual physicians. She sought to hold Sutter Health liable for negligent hiring or retention of one of the physicians. The court of appeal affirmed summary judgment for Sutter Health, holding that the absence of any claim for negligent hiring or retention in the operative complaint prohibited plaintiff from opposing summary judgment on that ground.
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