In 1985, a young woman named Libby Zion died in the emergency room of a large New York City teaching hospital. A grand jury was formed to investigate Zion's death. Although no criminal charges were filed, the grand jury specifically identified the house officers involved with this case as being directly responsible for the patient's death. The intern's chronic fatigue and the resident's lack of experience (a PGY-2 at the time) were found to be contributing factors.

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