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Helling v. Carey

Supreme Court of Washington
519 P.2d 981 (1974)


Facts

Helling (plaintiff) suffered from primary open angle glaucoma, a condition where fluids are unable to flow out of the eye. As a result, pressure gradually rises to a point where optic nerve damage results, as well as loss of vision. The condition comes with very few symptoms and is primarily detected through a pressure test performed on the eye. Helling saw her ophthalmologists, Drs. Thomas Carey and Robert Laughlin (defendants) for a number of years, including for regular appointments and the fitting of glasses and contact lenses. After years of seeing Carey and Laughlin for what she believed were issues and irritation caused by her contact lenses, Carey tested her eye pressure and field of vision. It was determined that Helling, then 32-years-old, had glaucoma resulting in some loss of vision. Helling filed suit against Carey and Laughlin alleging, among other things, that defendants’ negligence proximately caused the permanent damage to her eyes. At trial, expert witnesses from both sides testified that the standards of the profession did not require a pressure test to be given to patients under the age of 40 to determine the presence of glaucoma because the disease rarely occurs in individuals in that age group. The jury found in favor of Carey and Laughlin. The court of appeals affirmed the judgment and Helling petitioned to the state’s supreme court.

Rule of Law

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Issue

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Holding and Reasoning (Hunter, J.)

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  • A "yes" or "no" answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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