What is the current state of the law regarding notice of an emergency in a hospital?

Tellingly, the court in Simmons v. Tuomey Regional Medical Center (2000) 341 S.C. 32 [533 S.E.2d 312] (Simmons ) forecast an emerging trend concerning a hospital's ability to give meaningful notice in emergency circumstances. In sum, our decision is amply supported by law in other jurisdictions. Courts throughout the nation have struggled with this issue, and nearly all have held hospitals liable under one or more theories. The Ohio cases illustrate what we perceive to be the likely trend among the many courts that have adopted an

[237 Cal.App.4th 639]