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Memorial Hospital of Converse County v. Gates — Governmental Immunity Cap Applies to $3.2M Verdict

The Wyoming Supreme Court reversed the District Court of Converse County and held that Memorial Hospital of Converse County's liability for a medical malpractice verdict is capped at $1 million under the Wyoming Governmental Claims Act, notwithstanding a $3.2 million jury verdict. The Court rejected the plaintiff's argument that the Hospital had waived governmental immunity by operating a statewide commercial healthcare enterprise, finding the statutory limitation on the waiver of governmental immunity applies regardless. The Hospital and Dr. Jonathan L. Grosdidier had appealed after the district court entered judgment for the full $3.2 million verdict.