Hospital Liability: Nondelegable Duty in Hospital Emergency RoomsSimmons v. Tuomey Regional Medical Center]-The Court of Appeals for South Carolina held for the first time that hospitals have a nondelegable duty to render competent services to patients in their emergency rooms, even it the hospital statts its emergency room with independently contracted physicians.2 Like many other jurisdictions, South Carolina had once applied the doctrine of charitable immunity to shield its hospitals from tort liabilities.3 However, this court indicated that changing public policy considerations in the health care arena compelled it to conclude that a hospital's duty to its emergency room patients has …