Boyd v. Albert Einstein Medical Center

Chardella Boyd (plaintiff) signed up for a group health plan provided by Health Maintenance Organization of Pennsylvania (HMOP) (defendant). HMOP had brochures guaranteeing the quality care under its plan. Except for emergency situations, plan members were limited to choosing a primary doctor from a specific list. Also, a member needed to get a referral from a primary doctor before seeing a specialist. These limitations were cost-saving measures. The primary doctors who participated in the plan were independent contractors who were paid a certain amount for every member assigned to them. There was also a complex system that distributed the risk of the members’ actual treatment costs between HMOP and the participating doctors. Boyd visited her chosen primary doctor for a breast lump. This doctor referred Boyd to a specialist who also participated in the HMOP plan to biopsy the lump. The specialist accidentally poked Boyd’s chest cavity, and she was hospitalized for two days. After being released, Boyd continued to tell her HMOP doctors that she was having chest pain, fatigue, and vomiting issues. One night, Boyd woke with chest pain and went to the emergency room, where she was seen by one of her HMOP doctors. That doctor diagnosed Boyd with an inflammatory condition called Tietz’s syndrome. The doctor then scheduled Boyd to go to the doctor’s own office later for heart tests and sent her home to rest in the meantime. Having the tests at the doctor’s office created a delay but would be cheaper. When she got home, Boyd continued to have chest pain. Over the phone, Boyd’s HMOP doctor prescribed a pain medication. Several hours after being sent home from the hospital, Boyd died of a heart attack. Boyd’s estate and family sued the HMOP, arguing both that HMOP had breached its warranty of good health and that it was responsible for the malpractice of its participating doctors. The trial court ruled that Boyd had not presented facts that could make HMOP liable to Boyd for any malpractice and dismissed the case. Boyd appealed.