Law School Case Brief
Nat'l Health Labs., Inc. v. Ahmadi - 596 A.2d 555 (D.C. 1991)
When two tortfeasors jointly contribute to harm to a plaintiff, both are potentially liable to an injured party for the entire harm. As between themselves, however, through the principle of contribution, they share equally in satisfaction of the judgment.
Plaintiff Pari Ahmadi came to the Neurology Center (NC) complaining of numbness in her lower extremities. Wilner, her first physician, tentatively concluded that she had a vitamin B-12 deficiency or multiple sclerosis. Wilner sent a blood sample to the National Health Laboratories (NHL) for a vitamin B-12 test. Because of an admitted error in the testing methodology, the NHL technicians incorrectly reached a normal-range finding. Ahmadi had been admitted to George Washington University Hospital (GW) by another NC physician, Dr. Pulaski. On admission, a GW resident ordered a second vitamin B-12 level test, but the hospital staff never carried out the new test. Pulaski then relied on the normal-range result of the NHL’s test to rule out B-12 deficiency; he thereby made the probable diagnosis of multiple sclerosis. Ahmadi marginally improved with the outpatient treatment by NC’s Dr. Edelson but worsened again. The NC ruled out vitamin B-12 deficiency without conducting a new B-12 level test, instead suggesting risky drug treatment for multiple sclerosis. Ahmadi’s symptoms progressed, and seven months later, she was diagnosed with a B-12 deficiency by a fourth doctor when a new B-12 test came back at a dangerously low level. The patient became partially paralyzed.
Ahmadi brought suit against the NC for negligence and medical malpractice; against the NHL, for negligent failure to perform the B-12 test properly and for falsely reporting a normal result; and against GW for negligence in failing to complete a second B-12 test and failure to diagnose. The jury exonerated GW, but found for Ahmadi as against the NC and NHL, rendering a $10 million verdict against both. Previously filed cross-claims for contribution and indemnity by each liable defendant against the other were argued in a bench hearing. The trial court ruled that while each was entitled to contribution of 50% from the other, neither was entitled to indemnification under District law. In its appeal, NC challenged the trial court’s refusal to order the NHL to indemnify it for its half share of liability for Ahmadi’s injuries. According to NC, indemnification by the NHL was required as a matter of law, especially given the fact that NC’s negligence was a superseding cause.
Did a medical provider have the right to indemnity from the testing laboratory?
The Court ruled that, as a general rule, when two tortfeasors jointly contribute to harm to a plaintiff, both were potentially liable to the injured party for the entire harm. However, under certain circumstances, a trial court may require that one of the two tortfeasors bear, as against the other, sole responsibility for satisfaction of the judgment. Hence, the right to indemnity depended essentially upon the relationship between the parties, which may be expressly contractual or may be such that an obligation to indemnify, in a sense quasi-contractual in nature, may be fairly imposed. However, the Court determined that indemnification was not warranted because there was no special legal relationship between the NHL and NC as over time, NC could not reasonably rely on the normal-range test result. The Court averred that both NC and NHL were independently negligent in not ordering another B-12 test. As such, both NHL and NC were equally liable to satisfy the judgment.
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