DC Circuit Holds Temporary Nurses are ‘Employees’ for Purposes of Hospital’s General Liability Policy

In Interstate Fire & Casualty Company v. Washington Hospital Center Corp., the D.C. Circuit Court of Appeals affirmed a lower court decision holding that a temporary nurse hired to work at the Washington Hospital Center (the hospital) by a staffing agency was an “employee” of the hospital and therefore an “insured” under the Hospital’s general liability policy.

The hospital carried a $5 million general liability policy issued by Greenspring Financial Insurance Company. This policy defined an “insured” as “all past, present, or future full-time …

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