Expand the List of Hospital Apparent Agents? The Illinois Supreme Court Says Not So Fast

The Illinois Supreme Court’s decision in Yarbrough v. Northwestern Memorial Hospital reaffirmed limits on apparent agency liability, holding that a hospital is not responsible for the negligence of an independent clinic based solely on affiliations such as financial support, shared governance opportunities, or staff privileges. By grounding its analysis in the policy rationale of Gilbert v. Sycamore Municipal Hospital, the Court clarified that apparent agency depends on patient reliance arising from care provided at the hospital itself, not from indirect or off-site relationships.