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Lawrence v. Ingham County Health Department Family Planning/Pre-Natal Clinic

Michigan Court of Appeals
408 N.W.2d 461 (1987)


The Lawrences (plaintiffs) were pregnant and received prenatal care from the Ingham County Health Department Family Planning/Pre-Natal Clinic (Clinic) (defendant). The Lawrences’ daughter suffered prenatal asphyxia resulting in permanent brain damage. The Lawrences brought suit against the Clinic, alleging breach of an implied contract. Specifically, the Lawrences alleged that a contract was formed because the Clinic offered to provide the Lawrences with medical services “within the then-existing and applicable standards of care,” and the Lawrences accepted that offer by promising not to have an abortion and promising to follow the directions of the Clinic’s doctors. The Lawrences argued that their promises constituted consideration for the contract. The trial court granted the Clinic summary judgment. The Lawrences appealed.

Rule of Law


Holding and Reasoning (Kelly, P.J.)

Dissent (Sawyer, J.)

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