Muse v. Charter Hospital of Winston-Salem, Inc.

At the age of 16, Joe Muse was admitted to Charter Hospital (defendant) to be treated for depression and suicidal thoughts. Dr. L. Jarrett Barnhill, Jr., was his treating physician. Joe’s medical insurance expired on July 12. Barnhill ordered a blood test to determine the proper dosage of medication to treat Joe’s hallucinations and suicidal thoughts. The test was scheduled for July 13th, the day after Joe’s insurance expired. Barnhill requested that the hospital allow Joe to stay until July 14th and Joe’s parents signed a promissory note that they would pay for the extra days. The hospital discharged Joe on the 14th, but the results of his blood test did not come back from the lab until July 15th. There was dispute regarding whether Joe’s condition had improved when he was discharged or was worse than when he was admitted. Barnhill referred Joe to an area mental health clinic for outpatient treatment. Approximately two weeks later, Joe took a fatal overdose of one of his prescribed medications. Joe’s parents (plaintiffs) filed a wrongful death action against Charter Hospital. A jury found that the hospital was negligent in having a policy or practice of discharging patients when their insurance expired and that the practice interfered with the medical judgment of treating physicians. It awarded plaintiffs $100,000 in compensatory damages and $2 million in punitive damages. It also found that Charter Hospital’s parent corporation, Charter Medical Corporation, was an instrument of the hospital and assessed it punitive damages in the amount of $4 million. Defendants appealed to the court of appeals.