McCormick v. England
South Carolina Court of Appeals
494 S.E.2d 431 (1997)
- Written by Sean Carroll, JD
Facts
Dr. Kent England (defendant) was Sally McCormick’s (plaintiff) doctor. McCormick and her husband got divorced, and they were engaged in litigation to determine custody of their children. England wrote a letter to the divorce court about McCormick’s health. England wrote that McCormick suffered from major depression and alcoholism and that McCormick should be hospitalized. There is no indication that the court ordered England to write the letter or otherwise report on McCormick’s health. McCormick sued England for breach of confidentiality. The trial court dismissed the complaint for failure to state a claim, because South Carolina had not previously adopted the physician-patient privilege. McCormick appealed.
Rule of Law
Issue
Holding and Reasoning (Anderson, J.)
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