Ehrhart v. King County

CourtWashington Supreme Court
DecidedApril 2, 2020
Docket96464-5
StatusPublished

This text of Ehrhart v. King County (Ehrhart v. King County) is published on Counsel Stack Legal Research, covering Washington Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ehrhart v. King County, (Wash. 2020).

Opinion

FILE THIS OPINION WAS FILED FOR RECORD AT 8 A.M. ON APRIL 2, 2020 IN CLERK’S OFFICE SUPREME COURT, STATE OF WASHINGTON APRIL 2, 2020 SUSAN L. CARLSON SUPREME COURT CLERK

IN THE SUPREME COURT OF THE STATE OF WASHINGTON

SANDRA EHRHART, individually and as personal representative of the Estate of Brian Ehrhart,

Respondent, NO. 96464-5 v.

KING COUNTY, operating through its health department, Public Health–Seattle & King County, EN BANC

Petitioner,

and

SWEDISH HEALTH SERVICES, a non- Filed: APRIL 2, 2020 profit entity, and JUSTIN WARREN REIF, an individual,

Defendants.

STEPHENS, C.J.⸺This case concerns the tragic death of Brian Ehrhart, who

died within days of contracting hantavirus near his Issaquah home in early 2017.

His widow, Sandra Ehrhart, sued King County’s public health department, Swedish Ehrhart et al. v. King County et al., 96464-5

Medical Center, and an emergency room physician, arguing all three had negligently

caused Brian’s death.1 King County asserted the public duty doctrine as an

affirmative defense, arguing it was not liable for Brian’s death because it did not

owe him any duty as an individual. Ehrhart moved for partial summary judgment

asking the court to dismiss this defense and others. The trial court granted Ehrhart’s

motion but conditioned its ruling on the jury finding particular facts. King County

appealed, and we accepted direct discretionary review.

This interlocutory appeal asks us to resolve two questions: one procedural and

one substantive. The procedural question is whether the trial court could properly

grant summary judgment conditioned on the jury finding particular facts. We hold

it could not because summary judgment is appropriate only when there are no

genuine issues of material fact.

The substantive question—a question at the heart of the public duty

doctrine—is whether the regulations governing King County’s responsibility to

issue health advisories create a duty owed to Brian individually as opposed to a

nonactionable duty owed to the public as a whole. We conclude King County does

not owe an individualized duty to Brian and no exception to the public duty doctrine

1 Because Brian and Sandra Ehrhart share a surname, for clarity we refer to Brian by his first name and to the plaintiff Sandra Ehrhart by her surname.

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applies. Accordingly, we reverse the trial court’s ruling and remand for entry of

summary judgment in King County’s favor on its public duty doctrine defense.

FACTS

Hantavirus is a rare and serious infection transmitted by deer mice through

their droppings. It initially presents with flu-like symptoms such as fever and chills

but can quickly progress to life-threatening respiratory complications. Infected

patients may require intensive care, including intubation and oxygen therapy in cases

of severe pulmonary distress. There were more than 40 reported cases of hantavirus

in Washington in 2016, including 1 in King County.

In November 2016, a woman living near Issaquah contracted hantavirus. She

went to the urgent care facility at Group Health Cooperative, where she was treated

for nausea and discharged. She returned to Group Health the next day after her

condition deteriorated and was then admitted as a patient at Overlake Medical

Center. She spent several days in a coma, but she survived.

Overlake notified King County of that patient’s case in December 2016 and

King County promptly assigned a public health nurse to conduct an investigation,

which included a review of the patient’s medical records, interviews with her and

her husband regarding exposure and recent travel, and consultation with her

physicians. This investigation indicated that the patient had likely contracted

-3- Ehrhart et al. v. King County et al., 96464-5

hantavirus on her own property. Because the patient had not traveled out of the area

and the likely source of hantavirus exposure was confined to her rural land outside

Issaquah, King County determined there were no other likely exposures and so a

health advisory was not warranted. Over the course of this investigation, the

patient’s husband repeatedly shared with King County his concerns that a potential

cluster of hantavirus in the area could lead to more exposures.

In February 2017, Brian—who also lived near Issaquah—came to the

emergency room of Swedish Medical Center with fever, chills, vomiting, and a

persistent cough. The emergency room physician discharged Brian with instructions

to return if his symptoms worsened or if he had any additional concerns. The next

day, Brian was rushed to the emergency room at Overlake—several of his organs

were already failing. Brian died shortly thereafter.

PROCEDURAL HISTORY

In June 2018, Sandra Ehrhart filed suit on behalf of herself and Brian’s estate

against King County, the emergency room physician, and Swedish Medical Center,

alleging their negligence caused Brian’s death. Ehrhart argues WAC 246-101-505,

which requires King County to “[r]eview and determine appropriate action”

whenever it receives reports of certain serious conditions, created a duty that King

County breached by failing to issue a health advisory after it learned of the

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November 2016 case. King County asserted the public duty doctrine among other

affirmative defenses in its amended answer.

Ehrhart moved for partial summary judgment, asking the court to strike

several of King County’s defenses, arguing, among other things, that the “failure to

enforce” and “rescue doctrine” exceptions to the public duty doctrine applied. King

County moved for a continuance under CR 56(f) and CR 6(b), asking for time to

undertake discovery and file a cross motion for summary judgment on the public

duty doctrine, and arguing that the court should consider the motions together to

promote judicial economy. The court granted King County’s motion in part,

renoting Ehrhart’s motion for partial summary judgment. King County also filed its

cross motion for summary judgment on the public duty doctrine. But the trial court

did not consider King County’s cross motion for summary judgment alongside

Ehrhart’s motion for summary judgment during oral argument on September 28,

2018.

After that argument, the court ruled from the bench before issuing a brief

written order. The court began by saying it “ha[d] this sense of for[e]boding”

because “[t]he public duty doctrine ha[d] frustrated [the court] for years.” Verbatim

Transcript of Proceedings (Sept. 28, 2018) (VTP) at 19. The court briefly described

Washington’s waiver of sovereign immunity and the emergence of the discretionary

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immunity doctrine, and stated, “The public duty doctrine was essentially adopted

without any analysis . . . . And ever since then, there has been nothing but

inconsistency in the case law.” Id. at 20. The court explained, “There’s never really

been a good case where the Supreme Court or any other court of appeals has shown

us how to meld the original discretionary immunity analysis with the public duty

doctrine.” Id. The court tried to “meld” the doctrines itself, walking through the

analysis of discretionary immunity “for comparison purposes” and concluding the

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