Nearly one hundred thousand patient deaths per year are attributed to provider error, according to a November 1999 report by the Institute of Medicine of the National Academies. Overwork and exhaustion are sources of such errors. And among all doctors, the most overworked are medical residents–medical school graduates employed by teaching hospitals ostensibly to receive training in a medical specialty but, practically speaking, to be utilized as cheap labor. According to Jung v. Association of American Medical Colleges, a May 2002 lawsuit filed in a Washington, D.C., federal district court that challenges the residency employment system, typical medical resident work hours range from 60 to 136 per week. The starting hourly compensation rate calculates out at about $10 per hour on average. And the vast majority of U.S. medical residents aren’t represented by labor unions.