A Health Service Executive investigation into an incident in which a nurse put surgical tape over a patient's mouth found that his workload was inequitable, unreasonable and unsafe.
Bimbo Paden has pleaded guilty to assaulting the patient at St John's Hospital in Sligo last June.
However, Judge Kevin Kilraine said that he would not finalise sentencing in the case until a psychiatrist with expertise in stress assessed Paden.
Paden, 39, with an address at Cartron Point in Sligo, but originally from the Phillipines, apologised to patient Kevin Quinn and his family.
He admitted putting a small piece of surgical tape on 49-year-old Mr Quinn's mouth for a short time.
Paden told gardaí that he was looking after nine patients on his own and that one patient he was attending to appeared agitated and upset by Mr Quinn's constant shouting.
He said he asked Mr Quinn quietly to "shush" and rubbed his arm to reassure him. The shouting continued and he put a piece of tape on his mouth.
Mr Quinn's brother, Christy, told Sligo District Court today that his brother, who suffered a brain haemorrhage 13 years ago, is very vulnerable and incapacitated, and this was total abuse of a patient.
He said that when he visited his brother Kevin, he would always rub his face, but now he pulled away from him.
Christy Quinn said his brother had not been able to speak for 12 years, which the judge accepted, but said he could make other sounds.
The court was told that Paden, who is a married man with three young children, had been working at St John's for 12 years.
No complaint was ever made against him until this incident, which he described as a moment of complete stupidity.
A HSE investigation into the incident found that while there was no excuse for what the nurse had done, it appeared to have been out of character for him.
Solicitor Mark Mullaney, acting for Paden, said the incident shows the stark reality the nursing profession is working under in the current climate and the stress that he and others are under in a very difficult job.
Judge Kilraine said that Paden was working in an environment that appeared extremely stressful with each patient requiring detailed and intensive care, including wheelchairs and hoists.
He appeared to be working in a system that required the impossible to be done, the judge said, and it is hard to see how one person could be required to do this work in a safe manner.
The judge noted that Paden never complained about the stress before, but maybe he should have.
He said he had no doubt that the stress contributed to his actions and that he may have broken under the stress.
Judge Kilraine said: "What he had done was an utterly unacceptable thing to do to a vulnerable patient."
He remarked that Paden had been suspended since the incident and the question of his registration as a nurse is a live issue and his career is at risk over one particular incident.
The judge said the picture is one of a nurse under serious stress with inadequate, if any, management support.
He said the HSE report found that stress contributed to the incident, but did not say how much.
Judge Kilraine asked that a psychiatrist with expertise in stress produce a report on Paden before he finalises sentencing in the case.
