An article co-authored by Greenbaum attorneys John Zen Jackson and Madeline B. Gayle, recently published in the Widener Law Review, reviews the tragic circumstances surrounding Charles Cullen, the killer nurse who became known as the “Angel of Death” following the discovery of his role in the deaths of between 40 and 400 patients in New Jersey and Pennsylvania.  Limited pre-employment vetting and background checks combined with the lack of thorough investigations of suspicious circumstances allowed Cullen to change employment at several healthcare institutions without detection for approximately 15 years until his arrest in 2003. The article examines the ensuing litigation, as well as New Jersey’s legislative response which included the enactment of laws imposing a duty to disclose medical errors and report misconduct as well as an obligation on the part of healthcare entities to provide and obtain meaningful background and performance information concerning prospective employees. Mr. Jackson and Ms. Gayle also evaluate the limitations and unintended consequences of the Health Care Professional Responsibility and Reporting Enhancement Act (HCPRREA), also known as the Cullen Law.