Anderson v. St. Francis-St. George Hospital, Inc.

Supreme Court of Ohio · Torts

Tortsmedical batteryright to refuse treatmentcausationdamageswrongful livingmedical batterynegligence

Facts

Edward Winter had instructed that certain life-saving treatment not be administered, but a nurse defibrillated him during ventricular tachycardia and he survived. The record indicated that without the defibrillation he would have died on May 30, 1988. After surviving, Winter suffered additional medical problems, including a stroke, but the plaintiff's own evidence did not show that the defibrillation itself caused the stroke except insofar as it prolonged his life. Winter suffered no direct physical injury from the defibrillation itself, such as burns or broken bones.

Issue

When a medical provider administers life-prolonging treatment against a patient's express instructions, is the provider liable for all foreseeable consequential damages resulting from the patient's continued survival? More specifically, can a plaintiff recover for later injuries that occurred only because the patient lived longer, when those injuries were not caused by the treatment itself apart from prolonging life?

Rule

There is no independent cause of action for wrongful living. A patient subjected to unwanted life-saving treatment may proceed only under traditional negligence or battery principles, and causation is satisfied only as to the prolongation of life, not as to later injuries unless the treatment itself caused them. Continued living is not a compensable injury, and where an unwanted battery is physically harmless, only nominal damages are available.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Columbus, Nora Patel signed a clear directive refusing chest compressions and electrical resuscitation. During a cardiac arrest at Lakeview Medical Center, Dr. Evan Mercer ignored the directive, shocked her heart, and fractured two ribs and caused skin burns from the paddles; she survived for another month.

If Nora sues for battery and negligence, which damages are most likely recoverable under the governing rule?

Explanation. The majority held that there is no independent claim for wrongful living. A patient may recover only under traditional negligence or battery principles, and damages must be tied to harms directly caused by the unwanted treatment itself. Here, the unwanted resuscitation allegedly caused direct physical injuries—rib fractures and burns—so those damages are recoverable. But damages measured by the prolongation of life or by injuries flowing only from continued survival are not.