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.