McRell v. Central Phlebotomy Services, Inc.

30 Mass. L. Rptr. 75
CourtMassachusetts Superior Court
DecidedMay 18, 2012
DocketNo. WOCV201101577
StatusPublished

This text of 30 Mass. L. Rptr. 75 (McRell v. Central Phlebotomy Services, Inc.) is published on Counsel Stack Legal Research, covering Massachusetts Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McRell v. Central Phlebotomy Services, Inc., 30 Mass. L. Rptr. 75 (Mass. Ct. App. 2012).

Opinion

Ricclardone, David, J.

The plaintiff, Carole McRell (“McRell”), brings this suit against defendants, Central Phlebotomy Services, Inc. (“CPS") and Richard Haas, M.D. (“Haas”) claiming negligence (Count I) and battery (Count II) against CPS, as well as negligence (Count III) and battery (Count IV) against Haas. McRell alleges that a phlebotomist employed by CPS injured her during a routine blood draw. She further contends that the phlebotomist was Haas’s agent. Haas argues that the phlebotomist had no actual or apparent authority to act as his agent. This matter is now before the court on Haas’s motion for summary judgment on Counts III and IV. For the reasons set forth below, the defendant’s motion for summaiy judgment is ALLOWED in part and DENIED in part.

Background

The following facts are gleaned from the parties’ Joint Statement of Undisputed Facts and the summary judgment record.

Haas is an endocrinologist operating a sole proprietorship medical practice at 200 Lincoln Street in Worcester, Massachusetts. He shares an office suite with two other physicians. Four other medical providers practice in the same building.

CPS is a corporation that performs blood draws for medical providers. John Byrne (“Byrne”) serves as its president, CEO, and sole shareholder. Its business address is at 552 West Boylston Street in Worcester. In 2007, it employed about twenty people, the majority of whom were phlebotomists. CPS stationed one of its phlebotomists in the same office suite as Haas. Haas and other physicians in his building utilized CPS to perform blood draws.

CPS is a separate and distinct business from Haas’s medical practice although it did not display a sign or any other identification at Haas’s building. CPS, not Haas, was responsible for hiring and firing its phlebotomists. Haas did not train any of CPS’s phlebotomists. He never employed a phlebotomist in his office, beyond this arrangement with CPS.

In 2007, CPS employed a phlebotomist named Ditela Dhima (“Dhima”). It paid her an hourly wage.

On November 14, 2007, McRell visited Haas in connection with treatment for diabetes. Haas ordered a routine blood draw. Haas states that when he orders a blood draw, he gives the patient a choice between going to a laboratory of their choosing or having blood drawn at his office. McRell responds that Haas refers patients directly to labs for blood draws between patient visits. She contends that his usual practice is to have CPS technicians draw patients’ blood in his office [76]*76during the examination, in the same treatment room where the patient saw Haas.

Dhima performed McRell’s blood draw in Haas’s examination room. McRell alleges that Dhima attempted to draw blood improperly and struck a nerve in McRell’s left arm. This caused severe pain and lingering numbness and discomfort. McRell was told to see a neurologist at UMass Memorial Medical Center.

Haas was not present at the blood draw and has no memory of any conversation with Dhima regarding the blood draw. Haas states that he did not supervise the phlebotomists and that supervision was entirely the responsibility of CPS. He further avers that he did not direct Dhima as to how to draw blood. McRell responds that CPS expected its phlebotomists to follow the instructions of the physician who ordered the blood draw. In his deposition, Byrne stated that a physician might warn a phlebotomist that a patient was hesitant about the blood draw, or might provide information about a condition, such as a mastectomy, that the phlebotomist should be aware of before performing the procedure. McRell also notes that Haas admitted that if he saw a phlebotomist drawing blood incorrectly, he would express his concern to the phlebotomist. McRell states that Haas had addressed concerns with CPS phlebotomists in the past regarding issues such as availability and timeliness.

Haas did not regularly inform his patients that the phlebotomists at his office were not his employees. Haas said nothing to McRell about any employment relationship between himself and the phlebotomist. McRell did not ask Haas who employed Dhima or any of the other phlebotomists who performed her blood draws. McRell assumed the phlebotomist was Haas’s employee because she drew blood in his office suite. McRell states that CPS phlebotomists would wear lab coats or scrubs, with nothing to identify them as CPS employees. She avers that CPS only performed blood draws at the request of physicians that it had a relationship with, such as Haas. She further contends that CPS expected Haas to communicate any instructions or concerns directly to the phlebotomists.

Discussion

A. Count III: Batteiy: Issue of Consent

McRell alleges that Dhima committed battery against her when she performed the blood draw. To maintain an action for a battery, McRell bears the burden of proving that Dhima intended to bring about a harmful or offensive contact with McRell’s body, and that the harmful or offensive contact did occur. Waters v. Blackshear, 412 Mass. 589, 590 (1992). However, if McRell consented to this contact, her consent would bar her claim. Matter of Spring, 380 Mass. 629, 638 (1980). Consent in a claim of batteiy differs from that in a breach of informed consent. Erikson v. Garber, 2003 Mass.App.Div. 125, 126 (2003). While the issue in a breach of informed consent is whether the physician disclosed all material medical information to the patient to allow for an informed decision, the question in an action for batteiy is merely whether the patient consented to the contact in question. Id.

In the present case, McRell does not contest the fact that she consented to Dhima performing the blood draw. Although she contends that she only consented because she believed Dhima to be Haas’s employee, her reasons for consenting are not relevant to a batteiy claim. Id. The question of whether Haas failed to provide her with sufficient information, or whether her consent was inadequate, would only apply to a breach of informed consent. Id. McRell cannot maintain a batteiy claim when she consented to the touching in question. As a result, Haas is entitled to summary judgment on Count IV of McRell’s First Amended Complaint.

B. Count IV: Vicarious Liability; Issue of Agency

McRell also contends that Dhima was negligent in performing the blood draw. She argues that Haas must be held vicariously liable for Dhima’s conduct because Dhima was his agent. An agency relationship exists “when there is mutual consent, express or implied, that the agent is to act on behalf and for the benefit of the principal, and subject to the principal’s control.” Theos & Sons, Inc. v. Mack Trucks, Inc., 431 Mass. 736, 742 (2000), and cases cited.

“The right to control an agent’s activities has been the guiding principle in deciding cases involving an assertion of vicarious liability against the agent’s principal.” Kelley v. Rossi, 395 Mass. 659, 661 (1985). Clearly, Haas took a number of steps in order to avoid the creation of an agency relationship between himself and Dhima. Haas lacked the power to hire or fire Dhima. He did not employ her himself, and he did not pay her any wages, at least directly, for working out of his office suite. He did not set the terms of her employment even though he informed CPS of his requirements. He had no involvement in her training as a phlebotomist.

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Related

Hudson v. Massachusetts Property Insurance Underwriting Ass'n
436 N.E.2d 155 (Massachusetts Supreme Judicial Court, 1982)
In the Matter of Spring
405 N.E.2d 115 (Massachusetts Supreme Judicial Court, 1980)
Waters v. Blackshear
591 N.E.2d 184 (Massachusetts Supreme Judicial Court, 1992)
Kelley v. Rossi
481 N.E.2d 1340 (Massachusetts Supreme Judicial Court, 1985)
Theos & Sons, Inc. v. Mack Trucks, Inc.
729 N.E.2d 1113 (Massachusetts Supreme Judicial Court, 2000)
Dias v. Brigham Medical Associates, Inc.
438 Mass. 317 (Massachusetts Supreme Judicial Court, 2002)

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Bluebook (online)
30 Mass. L. Rptr. 75, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcrell-v-central-phlebotomy-services-inc-masssuperct-2012.