Brief Fact Summary. Against his doctor’s wishes, Muse was discharged from Charter Hospital of Winston-Salem, Inc. (Defendant), because his insurance had expired.
Synopsis of Rule of Law. Hospitals have a duty to not make policies or practices that require patients to be discharged against the medical judgment of a doctor because the patients insurance has expired.
An act is willful when it is done purposely and deliberately in violation of law or when it is done knowingly and of set purpose, or when the mere will has free play, without yielding to reason.View Full Point of Law
Issue. Do hospitals have a duty to not make policies or practices that require patients to be discharged against the medical judgment of a doctor because the patients insurance has expired?
Held. (Lewis, J.)Â Yes.Â Hospitals have a duty to not make policies or practices that require patients to be discharged, against the medical judgment of a doctor, because the patient’s insurance has expired.Â It is known that hospitals have a duty of care to their patients and must obey a doctor’s instruction.Â Hospitals are also required to make a reasonable effort to monitor and oversee the treatment prescribed.Â Therefore, it is clear that hospitals also have the duty not to discharge patients for insurance reasons if it interferes with the medical judgment of the patient’s doctor.Â In this case, the evidence at trial showed that Defendant had a policy of discharging patients when their insurance expired.Â The record also shows that Dr. Barnhill made it known to Defendant that he did not believe Joe should be discharged.Â The compensatory damages are affirmed.Â The punitive damages are reversed for other reasons.Â No error in part, reversed in part, and remanded.
Discussion. The court also ruled that the jury was correct in finding that the conduct of Defendant was willful and recklessly indifferent.Â This case goes beyond other decisions in defining the duty of a hospital.Â The decision seems based on the notion that health care mandates different types of duties because it is a different type of service.