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Miller v. HCA, Inc.

Supreme Court of Texas
118 S.W.3d 758 (2003)


Facts

Karla Miller (plaintiff) was admitted to the Woman’s Hospital of Texas (defendant) in premature labor. Physicians discovered that Karla had an infection, which posed a danger to her health if the fetus was not delivered soon. the doctors informed Karla and her husband, Mark, (plaintiffs) about the risks of inducing delivery of a fetus of 23-weeks gestation. The physicians told the Millers that the infant had little chance of being born alive and, if the baby survived, she would suffer severe and permanent physical and mental impairments. Millers decided that they did not want any heroic measures performed on the delivered infant, including resuscitation. Thereafter, the hospital administrators and physicians had a meeting to discuss the Millers’ situation and agreed that a neonatologist should be in the delivery room to decide whether to resuscitate the infant. Anna Summerfield, director of the neonatal intensive care unit, informed Mark that the hospital had a policy of requiring resuscitation of any baby born weighing over 500 grams. Summerfield asked Mark to sign a consent form allowing resuscitation to be performed but he refused. That evening, Karla’s condition worsened and physicians induced labor resulting in the birth of a baby girl, Sydney, weighing 615 grams. Life-saving treatment was administered to the baby by Dr. Otero, the attending neonatologist. Shortly after birth, Sydney, Karla’s baby, suffered a brain hemorrhage resulting in severe mental and physical impairments. The Millers sued Woman’s Hospital and its parent corporation, Hospital Corporation of America (HCA) (defendant) alleging battery and negligence. After a trial, a jury found that the HCA had acted without parental consent and awarded the Millers $29.4 million in actual damages for medical expenses, $17.5 million in prejudgment interest, and $13.5 million in exemplary damages. HCA appealed the trial court’s judgment and the court of appeals reversed. The Millers appealed.

Rule of Law

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Issue

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Holding and Reasoning (Enoch, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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