White v. Harris
Vermont Supreme Court
36 A.3d 203 (2011)
Fourteen-year-old Krystine White committed suicide after a suffering from a mental illness for a long period of time. During the course of her mental health treatment, Krystine enrolled in a telepsychiatry research study conducted by Mark Harris, M.D. (defendant), an employee of Fletcher Allen Health Care, Inc. (FAHC) (defendant). As part of the study, Krystine participated in a one-time, 90-minute video-conference session with Harris. Afterwards, Krystine completed a questionnaire about her experience. Thereafter, Harris completed a consultation evaluation that described Krystine’s illness, provided his diagnostic impression, and set forth a treatment plan. However, Harris did not provide any further follow-up clinical services to Krystine and no medications were prescribed. Additionally, Harris provided his recommended treatment plan to Krystine’s regular group of treating physicians. After her death, Krystine’s father, Terrence White (plaintiff) filed a wrongful death action against Harris and FAHC. White argued that Harris’s treatment of Krystine fell below the required standard of care of a skillful physician. Harris and FAHC claimed that Harris did not have a doctor-patient relationship with Krystine. The trial court granted summary judgment to Harris and FAHC. White appealed.
Rule of Law
Holding and Reasoning (Per curiam.)
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