The difficulties NHS employers have in reconciling duties towards patients and employees may be taken into account (King v Sussex Ambulance NHS Trust [2002] EWCA Civ 953), but this is not always the case (Knott v Newham Healthcare NHS Trust [2002] EWHC 2091 (QB)). In the first case, an ambulance technician injured his back while carrying a patient downstairs, but the court ruled that the ambulance service had not been negligent in its approach.