The U.S. Court of Appeals for the Tenth Circuit is reviewing a workplace safety dispute between Cedar Springs Hospital, Inc. and federal regulators over the healthcare facility's obligation to protect workers from violent patients. The case, filed Feb. 13, 2026, challenges a decision by the Occupational Safety and Health Review Commission that found the hospital failed to implement adequate safety measures.
According to court documents, the dispute arose when Cedar Springs Hospital employees encountered "seriously disturbed individuals who sometimes acted violently." The Secretary of Labor determined that the hospital had failed to implement safety measures that would have been both effective and feasible in protecting workers from these violent incidents.
The case presents two key legal questions for the appellate court: whether the Secretary of Labor had the authority to penalize the employer for failing to adopt the recommended safety measures, and whether the Secretary acted appropriately in the enforcement action. Circuit Judge Bobby R. Bacharach is writing the opinion for a three-judge panel that also includes Circuit Judges Timothy M. Tymkovich and Allison Jones Rushing Phillips.
The legal challenge highlights ongoing tensions between healthcare facilities and federal workplace safety regulators over how to balance patient care needs with employee protection requirements. Healthcare workers face unique safety risks, particularly in psychiatric and emergency care settings where patients may exhibit unpredictable or aggressive behavior.
Under the Occupational Safety and Health Act, employers have a general duty to provide workers with a workplace "free from recognized hazards that are causing or are likely to cause death or serious physical harm." This general duty clause has been increasingly applied to workplace violence issues, particularly in healthcare settings where workers face elevated risks from patients.
Cedar Springs Hospital is represented by Dion Y. Kohler of Jackson Lewis P.C. in Atlanta, a firm known for defending employers in workplace safety matters. The hospital's legal team is challenging both the underlying citation and the Review Commission's affirmation of the Secretary's enforcement action.
The Department of Labor is represented by Leigh Anne Schriever from the Office of the Solicitor, working alongside Solicitor of Labor Seema Nanda, Associate Solicitor Edmund C. Baird, and appellate counsel Louise McGauley Betts. The government's legal team will defend the Review Commission's decision and argue that the hospital's safety measures were inadequate.
The case reflects broader challenges facing healthcare employers in implementing workplace violence prevention programs. Federal regulators have increasingly scrutinized healthcare facilities' safety protocols, particularly following high-profile incidents of workplace violence against medical personnel.
OSHA has issued guidance encouraging healthcare employers to develop comprehensive workplace violence prevention programs that include hazard assessment, employee training, incident reporting systems, and environmental controls. However, hospitals often argue that some recommended measures may conflict with patient care requirements or be impractical in clinical settings.
The intermittent nature of the violence described in the court documents presents particular challenges for safety planning. Unlike consistent workplace hazards, violent incidents involving patients can be unpredictable and may require flexible response protocols rather than fixed safety measures.
The Review Commission's decision to uphold the Secretary's citation suggests that regulators found the hospital's existing safety protocols insufficient given the known risks. The Commission typically considers factors such as the feasibility of proposed safety measures, their potential effectiveness, and whether the employer demonstrated good faith efforts to address identified hazards.
For Cedar Springs Hospital, the appellate challenge represents an opportunity to establish precedent regarding the extent of employers' obligations to protect workers from patient-related violence. A favorable ruling could provide healthcare facilities with more flexibility in designing safety programs tailored to their specific operational needs.
Conversely, if the Tenth Circuit upholds the Review Commission's decision, it would strengthen federal regulators' authority to mandate specific safety measures in healthcare settings. This could lead to more aggressive enforcement actions against facilities deemed to have inadequate workplace violence prevention programs.
The case also raises questions about the appropriate balance between patient rights and worker safety in healthcare settings. Some safety measures, such as physical restraints or enhanced security presence, may impact the therapeutic environment or patient privacy rights.
Industry observers will closely watch the Tenth Circuit's decision for guidance on how courts interpret employers' general duty obligations in healthcare settings with inherent violence risks. The ruling could influence OSHA enforcement strategies and shape how healthcare facilities approach workplace safety planning.
The appeal process allows Cedar Springs Hospital to present arguments that may not have been fully considered during the initial Review Commission proceedings. The hospital's legal team will likely argue that existing safety measures were reasonable given the clinical setting's constraints and that additional requirements would be either ineffective or impractical.
As healthcare worker safety remains a priority for federal regulators, this case represents a significant test of how far authorities can go in mandating specific safety protocols. The Tenth Circuit's eventual ruling will provide important guidance for healthcare employers navigating the complex intersection of patient care obligations and worker protection requirements.