"HMOs Can Be Vicariously Liable for Their Independent Contractors' Negligence"
"The Illinois Supreme court held that under the doctrines of apparent and implied authority, HMOs may be liable for their independent contractors' negligence. Lynn D. Dowd and Robert J. Napleton, both of Chicago, Ill., represented plaintiffs." Petrovich v. Share Health Plan, Inc., 719 N.E.2d 756 (Ill. 1999).