California, United States of America
The following excerpt is from Demma v. Dominican Hosp., H038321 (Cal. App. 2013):
Courts have consistently upheld a broad interpretation of what constitutes "professional negligence," such that it encompasses not only the actions of a highly skilled physician, but also the acts of staff members employed by licensed healthcare providers, so long as the act of negligence occurred in the rendering of healthcare services for which the provider is licensed. (Palmer v. Superior Court (2002) 103 Cal.App.4th 953, 957 [professional negligence found in negligent recommendation made
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