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Renslow v. Mennonite Hospital

Illinois Supreme Court
367 N.E.2d 1250 (1977)


Facts

Emma Renslow (plaintiff) had Rh-negative blood. When Renslow was 13 years old, she received two blood transfusions from Mennonite Hospital (defendant), both of which contained Rh-positive blood. Renslow did not suffer any physical reaction to the Rh-positive blood, but the transfusion sensitized her blood. Eight years later, Renslow discovered her sensitization when she received prenatal care during pregnancy. Renslow’s blood condition jeopardized the life of her baby and made it necessary for Renslow to give birth prematurely to her child. Renslow’s baby suffered brain damage, and damage to her nervous system and other organs. Renslow, individually and on behalf of her child, Leah, sued the hospital for negligence. The trial court dismissed the suit. The trial court reasoned that the hospital did not owe a duty of care toward Leah because Leah was not conceived at the time of the hospital’s allegedly negligent transfusions. Renslow appealed. The appellate court reversed, holding that a duty arose between the hospital and Leah because the risk of the transfusions’ harm to Renslow’s future child was reasonably foreseeable. The hospital appealed.

Rule of Law

Issue

Holding and Reasoning (Moran, J.)

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