Knight v. Penobscot Bay Medical Center

William and Kathleen Knight (plaintiffs) went to Penobscot Bay Medical Center (hospital) (defendant) when Kathleen was expected to give birth. Dr. Albert Lantinen (defendant) and a nurse, Sandra Robie (defendant), were assigned to the birth. Sandra was working late because another nurse was delayed in relieving Sandra. Accordingly, when Sandra’s husband, Theodore Robie (defendant), arrived to drive Sandra home, he had to wait. To give Theodore something to do while he waited, Lantinen allowed him to watch a birth. Lantinen initially had Theodore watch a particular birth, but when complications arose, he had Theodore watch Kathleen’s birth. Theodore watched through a viewing window and did not see the actual process of delivery. Sandra and Theodore later testified that they thought they had authorization to observe the birth. Similarly, Lantinen testified that he did not intend to intrude on the Knights’ privacy. The Knights sued the hospital, Lantinen, and the Robies for, among other things, invasion of privacy. At trial, the Knights requested a jury instruction stating that the Knights had a legal right to privacy in the delivery room, which others could not violate unless intrusion was necessary and with consent. The trial court refused to give the instruction. The jury returned a verdict for the hospital, and the Knights appealed, claiming that the court erroneously denied the instruction.