University of Cincinnati Hospital v. Edmond

506 N.E.2d 299, 30 Ohio Misc. 2d 1, 30 Ohio B. 73, 1986 Ohio Misc. LEXIS 61
CourtCourt of Common Pleas of Ohio, Hamilton County
DecidedApril 21, 1986
DocketNo. A-8402286
StatusPublished

This text of 506 N.E.2d 299 (University of Cincinnati Hospital v. Edmond) is published on Counsel Stack Legal Research, covering Court of Common Pleas of Ohio, Hamilton County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
University of Cincinnati Hospital v. Edmond, 506 N.E.2d 299, 30 Ohio Misc. 2d 1, 30 Ohio B. 73, 1986 Ohio Misc. LEXIS 61 (Ohio Super. Ct. 1986).

Opinion

Kraft, J.

This matter came to the court upon a complaint for declaratory judgment and temporary relief filed on March 19, 1984, in which the plaintiff, University of Cincinnati Hospital, set forth the following:

• “1. Plaintiff University of Cincinnati Hospital, operates University Hospital, which is located at 234 Goodman Street, Cincinnati, Ohio. Defendant Marthelma Edmond, is female, over the age of 18, and a patient at the University Hospital.
“2. Defendant is presently confined at the University Hospital for injuries suffered as a result of a gunshot wound to her liver.
“3. Defendant was admitted to University Hospital on Thursday, March 15,1984, and underwent two operations on Friday, March 16, 1984, for treatment of her injuries. The Defendant presently is in critical condition and is in need of both blood and plasma treatment at this time. Unless she is able to receive blood and plasma, her life will be endangered. Failure to give her blood and plasma, as required, will, in the opinion of Plaintiff, result in Defendant’s death.
“4. Said Defendant is not presently competent and is unable to understand or give informed consent for the infusion of blood and plasma.
[2]*2“5. If Plaintiff fails to provide the necessary blood and plasma as is needed by Defendant, it may be held responsible for the Defendant’s death.
“6. The Defendant has not indicated to Plaintiff her position with regard to receiving blood and plasma, although certain persons related to Defendant have informed. Plaintiff that Defendant is a Jehovah’s Witness and that she is opposed to receiving either blood or plasma, although necessary to preserve her life.
“7. Because of Defendant’s deteriorated physical condition; and because of her inability to give informed medical consent to receive infusions of both blood and plasma, and because Plaintiff has been informed that Defendant is a Jehovah’s Witness, yet has no notification from the Defendant as to her position with regard to receiving blood and plasma, the Plaintiff seeks to provide the necessary medical treatment in order to save the Defendant’s life, including the infusion of blood and plasma; and time is of the essence; and Plaintiff has no adequate remedy at law and irreparable harm will result to the Defendant if Plaintiff is not permitted to provide the necessary blood and plasma as Defendant’s condition require[s]; and the Plaintiff seeks an Order granting permission to administer both blood and plasma to Defendant as is necessary without a written or oral notice to the Defendant because of the immediate and irreparable injury and loss that will result, being the death of the Defendant.
“WHEREFORE, Plaintiff prays for an Order authorizing it to administer the necessary treatment to the Defendant, including the administering of blood and plasma, so as to maintain her life. Plaintiff further seeks, upon final hearing, to have the Court declare the rights of the parties and for such other relief as may be just and equitable.”

Counsel for the plaintiff requested an immediate hearing on its prayer for relief. Said hearing was set for March 20,1984, at 1:45 p.m., the day after the filing of the complaint. At said hearing, plaintiff’s counsel was present as well as four adult children of the defendant, one Betty Dockery, age thirty-three; Samuel Edmond, age thirty; Lavada Edmond, age thirty-one; and Nadine West, age twenty-three. The court confirmed that notice of the hearing had been provided the four identified adult children of the defendant. They indicated that no effort had been made by them to secure counsel for the purpose of this hearing and there was no desire to delay the hearing to do so. The identified children of the defendant requested a closed hearing which the court denied as there was nothing presented to suggest that any prejudice would result from an open proceeding. The court did acknowledge, on the record, the presence of at least one photographer in the courtroom and therefore advised the identified children that they along with any other witnesses who testified would individually be given the privilege of indicating their desire not to be photographed as provided in C.P. Sup. R. 11 and Rule 3A(7) of the Code of Judicial Conduct.

The court then proceeded with an evidentiary hearing on the request for relief and permitted the four identified adult children to participate in the examination of all witnesses, to testify themselves and to offer other testimony in behalf of the defendant. At the evidentiary hearing, the plaintiff offered the testimony of Paul Glen, a physician, and George Luthringer, a patient representative of the plaintiff hospital. Plaintiff also offered an affidavit of one Dr. Popp which was refused admission by the court. The court then gave the adult children of the defendant the opportunity to offer evidence. Three of them, Samuel Edmond, Lavada Edmond and Betty Dockery did testify. In addition, they offered the testimony of one Andrew Waters identified as an [3]*3Elder of the Church of Jehovah’s Witnesses and one Eugene D. Stredrick identified as a member of the congregation of Jehovah’s Witnesses. After arguments made by counsel for plaintiff as well as by two of the defendant’s children, the court stated the following:

“In preparation for this hearing the Court reviewed the law which it believed might be applicable to the facts as set out in the complaint. First, it is instructive to suggest that no case law directly on point could be found in Ohio. The Court did review the case of In the Interest of Kenneth Clark, a Minor, decided by the Court of Common Pleas of Lucas County on September 22, 1962, and reported in [90 Ohio Law Abs. 21,] 21 [O.O.] 2d 86. That decision dealt with a 3-year-old who was a Jehovah’s Witness. The issue of blood transfusions was also involved. However, that case is clearly distinguishable from the one before the court today. There are specific statutes in Ohio which deal with the subject of emergency medical and surgical treatment when a minor is involved. [R.C. 2151.33.] There is no such statute when an adult is involved. We have, therefore, had to look elsewhere for assistance.
“The developing and currently prevailing law in the country which applies to an adult who is found to be not competent and not capable of expressing his/ her own specific preferences is applicable to this situation. [American Jurisprudence 2d (1979), New Topic Service, Right to Die, Wrongful Life, Section 7, Right to Refuse Lifesaving Medical Treatment.] The evidence herein is that the defendant, when admitted into the plaintiff’s hospital, was not capable of expressing her own specific wishes on the subject of the administration qf blood transfusions and/or plasma due to the ingestion of excessive amounts of alcohol as well as to a serious gunshot wound. There is no evidence to indicate that she is, at this moment in time, in a condition to personally express her own preferences for medical treatment, while there is ample evidence to indicate that her condition is critical and could become life-threatening at any time. The relevant question in this case therefore becomes whether there is a compelling state interest in life which would justify the state in acting to treat the defendant in a manner which, it is represented by others, is against the defendant’s religious beliefs. [John F. Kennedy Memorial Hospital v. Heston (1971), 58 N.J.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

John F. Kennedy Memorial Hospital v. Heston
279 A.2d 670 (Supreme Court of New Jersey, 1971)
In re Clark
185 N.E.2d 128 (Lucas County Court of Common Pleas, 1962)

Cite This Page — Counsel Stack

Bluebook (online)
506 N.E.2d 299, 30 Ohio Misc. 2d 1, 30 Ohio B. 73, 1986 Ohio Misc. LEXIS 61, Counsel Stack Legal Research, https://law.counselstack.com/opinion/university-of-cincinnati-hospital-v-edmond-ohctcomplhamilt-1986.