LA ex rel. SA and LA v. Division of Youth and Family Services

In January 2001, two-year-old SA was brought to the Jersey Shore University Medical Center (JSUMC) (defendant) emergency room by two men who claimed to be relatives. SA was vomiting and unable to walk. Doctor Daniel Yu (defendant) examined SA and noted that her mouth smelled like cologne and chemical alcohol. A blood test revealed that SA had a blood alcohol level of .035 percent. SA’s father then arrived at the hospital with the bottle of cologne. Yu diagnosed SA with accidental cologne ingestion. SA was then released to her father. The following month, SA was treated for a chemical burn on her foot at another medical facility. In March 2001, the Division of Youth and Family Services (DYFS) received a phone call that SA had burns and belt marks on her body. DYFS determined that SA had been abused but did not remove her from the home. In April 2001, DYFS received a call reporting that SA was hanging from a hook with her hands tied together and had multiple bruises and burns on her body. SA was then removed from the home and eventually adopted by LA (plaintiff). LA, as SA’s adoptive parent, filed a complaint against multiple parties for breaching a duty of care owed to SA. At the time the case was litigated, the only defendants were Yu and JSUMC because of settlement agreements. The complaint alleged that Yu had breached his statutory duty to report to DYFS that SA had been abused. Yu and JSUMC filed a motion for summary judgment. The trial court concluded that no reasonable jury could find that Yu had reasonable cause to believe that child abuse had occurred and granted the motion. The appellate division reversed. Yu and JSUMC appealed on the ground that the appellate division had misconstrued the statutory reporting requirements imposed on a physician. The New Jersey Supreme Court granted certiorari.