Muse v. Charter Hospital Of Winston-Salem, Inc.

452 S.E.2d 589 (1995)

Facts

Joe, who was sixteen years old, was admitted to D for treatment related to his depression and suicidal thoughts. Joe's treatment team consisted of Dr. Barnhill, as a treating physician, Fernando Garzon, as a nursing therapist, and Betsey Willard, as a social worker. During his hospitalization, Joe experienced auditory hallucinations, suicidal and homicidal thoughts, and major depression. Joe's insurance coverage was set to expire on 12 July 1986. As that date neared, Dr. Barnhill decided that a blood test was needed to determine the proper dosage of a drug he was administering to Joe. The blood test was scheduled for 13 July, the day after Joe's insurance was to expire. Dr. Barnhill requested that the hospital administrator allow Joe to stay at Charter Hospital two more days, until 14 July, with P's signing a promissory note to pay for the two extra days. The test results did not come back from the lab until 15 July. Joe was discharged on 14 July and was referred by Dr. Barnhill to the Guilford County Area Mental Health, Mental Retardation, and Substance Abuse Authority for outpatient treatment. Joe's condition upon discharge was worse than when he entered the hospital. Ds' evidence tended to show that while his prognosis remained guarded, Joe's condition at discharge was improved. Upon his discharge, Joe went on a one-week family vacation. On 22 July he began outpatient treatment at the Mental Health Authority, where he was seen by Dr. David Slonaker, a clinical psychologist. Two days later, Joe again met with Dr. Slonaker. Joe failed to show up at his 30 July appointment, and the next day he took a fatal overdose of Desipramine, one of his prescribed drugs. Ps sued Ds for wrongful death. The jury found that Charter Hospital (D) was negligent in that it had a policy that required physicians to discharge patients when their insurance expired and that this policy interfered with the exercise of the medical judgment of Joe's treating physician. The jury awarded Ps compensatory damages of approximately $1,000,000. The jury found that Ps were contributorily negligent, but that Charter Hospital's (D) conduct was willful or wanton, and awarded punitive damages of $2,000,000 against Charter Hospital (D). The jury found that Charter Hospital was an instrumentality of the defendant Charter Medical Corporation (D) and awarded punitive damages of $ 4,000,000 against Charter Medical (D). Ds appealed.