A 1986 legal case involving the death in 1984 of an 18-year old woman, Libby Zion, in New York. The woman died a few hours after admission to a hospital from its emergency department. Ms. Zion’s father claimed that her care had been inadequate, and a grand jury investigation later followed. While the grand jury did not return a criminal indictment, it did make a number of recommendations regarding emergency room staffing, supervision of physicians in training, regulation of work hours for interns and junior resident physicians, restraint of patients (and the care of patients under restraint), and protection of patients from contraindicated combinations of drugs. Each recommendation-particularly that of limiting the number of hours a physician in training may work consecutively-has attracted a good deal of attention in New York and nationally.