Shaker Medical Center Hospital v. Phillips

376 N.E.2d 983, 54 Ohio Misc. 21, 8 Ohio Op. 3d 338, 1978 Ohio Misc. LEXIS 70
CourtShaker Heights Municipal Court
DecidedJanuary 11, 1978
DocketNo. 77 CI F2858
StatusPublished
Cited by1 cases

This text of 376 N.E.2d 983 (Shaker Medical Center Hospital v. Phillips) is published on Counsel Stack Legal Research, covering Shaker Heights Municipal Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Shaker Medical Center Hospital v. Phillips, 376 N.E.2d 983, 54 Ohio Misc. 21, 8 Ohio Op. 3d 338, 1978 Ohio Misc. LEXIS 70 (Ohio Super. Ct. 1978).

Opinion

Booker, J.

Plaintiff rendered services in its Emer-;geney Boom to defendant, Phillips, in the early morning hours of September 27, 1976. The services consisted of faking a brief medical history, simple physical examination procedures such as blood pressure, temperature, pulse heat and other similar routine tests, all of which was done in a period of approximately one-half hour.

Upon completion of the examination, the hospital resident advised defendant to come back later in the day for ■further examination to “rule out peptic ulcer disease.” Plaintiff was given a dosage of “Maalox” to relieve intestinal distress and was also administered “Percodan,” a ■drug for relief of pain; he was then released from the hospital.

The hospital later submitted its fee bill to third-party defendant, Blue Cross of Northeast Ohio, in the amount of $62. Blue Cross rejected the claim as one not [22]*22covered under its policy with the state of Ohio for the benefit, of state employees and qualifying members of their families. The hospital, thereupon, directed its billing to defendant, Phillips, who upon being sued by plaintiff, joined Blue Cross as a third-party defendant.

Blue Cross of Northeast Ohio furnishes to each person covered under its group hospital and major medical policy a “benefits” book which outlines the coverages afforded. Among those coverages is one described as “treatment of a medical emergency.”

The benefits booklet defines under what circumstances a “medical emergency” compensable under its policy exists. The definition is as follows:

“Benefits are provided for the treatment of a medical emergency. A medical emergency will be considered to exist when there is a sudden and unexpected onset of a serious medical condition with symptoms so severe as to cause a person to seek immediate medical attention regardless of the hour of the day or night and when failure to obtain immediate medical care would cause serious harm to the patient’s health or jeopardize his life. To qualify for medical emergency coverage, the patient must have a sudden, unexpected condition which involves actual hazard to his life or health.
“The situation must involve a true emergency according, to the following guidelines:
... “ — The medical emergency must be sudden and unexpected with severe symptoms which causes you to seek immediate aid or treatment.
“ — The illness or condition as finally diagnosed and/or as indicated by its symptoms must be one which would normally require immediate medical care.
“Examples of such conditions or cases are heart attacks, strokes, poisonings, respiratory distress, suffocation, convulsions, hemorrhage, unconsciousness, diabetic acidosis, spontaneous lung collapse, acute appendicitis, acute severe infections, or heat prostration.
“Chronic conditions, that is, conditions of long duration .or frequent occurrence, generally, would not qualify [23]*23for medical emergency coverage unless there was an acute attack which would seriously jeopardize the life or safety of the patient.”

The patient medical history taken by the hospital physician relates the fact that defendant had a history of duodenal ulcer. At trial that history was more adequately described when defendant testified that the prior ulcer experience was incurred while in the military service some seven years ago. He further related that medical treatment at that time effectively healed the ulcer and that he had no other episodes of the illness since then.

Additional facts relating to the cause of defendant coming to the emergency room of the hospital at 4:45 a. m. were elicited at trial as follows:

1. Two nights previous to coming to the hospital, defendant had consumed a substantial amount of: alcoholic beverages at a social function.

2. The night before coming to hospital, defendant had eaten a heavily-spiced dinner.

Based upon those facts and examination, the emergency room physician reported his impression of the patient’s illness as “Gastritis — E/O PUD” which was translated at trial to mean that the doctor’s opinion was that the patient had an inflammation of the stomach and that further examination was recommended to rule out peptic ulcer disease.

The emergency room physician reported no evidence of heart attack, stroke, poisoning, hemorrhage, suffocation or any one of the other examples set forth in the guidelines of a “true emergency.”

Based upon the medical report, a physician employed parttime by Blue Cross as a medical review consultant rendered an opinion that no emergency existed.

The consultant’s view is succinctly stated in his testimony : “From the record that we have, I cannot state that he had any hazard to his life or was [in] an emergency situation.”

Later in cross-examination, the same witness was asked: “And absent any further medical substantiation other [24]*24than this emergency medical report, can yon really say what was wrong with that patient that night?” The witness responded: “No.” In answer to the another question, the witness testified that the emergency room physician according to the report suspected a gall bladder attack.

With respect to defendant, Phillips, seeking relief from pain during the night, the medical consultant stated that “often people wake up with something in the middle of the night and medically it certainly may not be an emergency situation, but to the patient it is and we have to factor that in.” (Emphasis added.)

The medical consultant continued with: “* * * because I may wake up — or somebody not being a doctor may wake up with a severe headache, as a layman, I may think I am having a stroke and I rush to the emergency room but its only headache and here, again, we get caught in this problem of using the emergency room as an out-patient service rather than a true emergency.”

When asked whether the consultant had an opinion as to the completeness of the physical examination given the patient, he responded that for the problem presented it was complete although no cardiogram or chest x-ray was administered.

Those responses indicate that coverage under the policy for emergency room services is a subject for decision first by the patient. He must make an evaluation of his symptoms and decide upon the risk of jeopardizing his life or health or expending the funds for a physician’s evaluation at an emergency room.

The consultant further in his testimony confirmed the fact that a patient who comes in with a duodenal ulcer history is one in whom the physician looks for some emergency developing in regard to that disease. The consultant stated: “Now, as far as emergency problems or complications from a duodenal ulcer, the main ones we run into are perforation of the ulcer, which would present an acute abdonminal catastrophe with severe pain, and there are certain physical findings■ that would indicate rupture of the ulcer.” (Emphasis added.)

[25]*25The consultant, listed numerous other .symptoms which, would present serious emergency situations with,, respect particularly to a patient having a history of. duodenal ulcer, disease, symptoms which physicians, generally, are trained to recognize. ..... •

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Cite This Page — Counsel Stack

Bluebook (online)
376 N.E.2d 983, 54 Ohio Misc. 21, 8 Ohio Op. 3d 338, 1978 Ohio Misc. LEXIS 70, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shaker-medical-center-hospital-v-phillips-ohmunictshakerh-1978.