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Laboratory Corporation of America v. Hood

395 Md. 608, 911 A.2d 841 (2006)

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Laboratory Corporation of America v. Hood

Court of Appeals of Maryland

395 Md. 608, 911 A.2d 841 (2006)

Facts

Laboratory Corporation of America and Laboratory Corporation of America Holdings (LabCorp) were North Carolina corporations in the business of providing medical-testing services. Maryland residents Karen and Scott Hood (plaintiffs) received testing services from LabCorp related to Karen’s pregnancy. LabCorp misread a report in North Carolina indicating that Karen’s unborn child did not have cystic fibrosis, a severe genetic disease. After LabCorp’s faulty assessment, the Hoods’ son, Luke, was born with cystic fibrosis. The Hoods filed a wrongful-birth suit in federal district court for the district of Maryland. The district court applied the substantive law of Maryland to the case, reasoning that Maryland was the state in which the last event required to give rise to the tort occurred. LabCorp argued that the standard-of-care exception in § 380(2) of the Restatement (First) of Conflicts of Law applied, and the exception required the district court to consider North Carolina law to determine whether its employees breached a duty owed to the Hoods. The district court certified two questions to the Court of Appeals of Maryland: (1) whether the district court should apply the standard-of-care exception, and (2) whether denying a Maryland resident’s wrongful-birth claim by applying North Carolina law would violate the public policy of Maryland.

Rule of Law

Issue

Holding and Reasoning (Wilner, J.)

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