Blatz v. Allina Health System
622 N.W.2d 376 (2001)
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Rule of Law:
When a professional, such as a paramedic, performs a non-medical function that does not require professional judgment or training, the standard of care is that of an ordinary reasonable person, not a heightened professional standard. A professional standard of care applies only when the professional is furnishing medical treatment or performing tasks that require their specialized skills.
Facts:
- On June 18, 1995, Mary Blatz experienced severe chest pains and difficulty breathing at her home in Jordan, Minnesota, a few days after undergoing knee surgery.
- Her husband, Patrick Sherman, called 911 at approximately 8:50 a.m.
- An ambulance from Allina Health System (doing business as HealthSpan) was dispatched at 8:53 a.m.
- Sherman began administering CPR to Blatz after she stopped breathing, just before a sheriff's deputy arrived.
- The HealthSpan paramedics, while on the correct street, became confused by the house numbering and could not see the final mailbox in a cul-de-sac.
- Instead of proceeding to the end of the road, the paramedics executed a three-point turn, drove back to the main road to check another address, and then returned after the dispatcher confirmed the correct address.
- This navigational error resulted in a delay estimated to be between one and a half to five minutes.
- The delay in receiving oxygen caused Blatz to suffer a severe and permanent anoxic brain injury.
Procedural Posture:
- Mary Blatz and Patrick Sherman sued Allina Health System in Scott County district court (trial court) for negligence.
- Following a trial, the jury returned a verdict finding Allina was negligent and that its negligence directly caused Blatz's injuries.
- Allina filed post-trial motions for judgment notwithstanding the verdict (JNOV), a new trial, and a Schwartz hearing to investigate juror responses.
- The district court denied all of Allina's post-trial motions.
- Allina (as appellant) appealed the district court's judgment and denial of its motions to the Minnesota Court of Appeals (intermediate appellate court), with Blatz and Sherman as appellees.
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Issue:
Does the ordinary reasonable person standard of care, rather than a heightened professional standard, apply to paramedics when they are performing non-medical functions such as navigating to an emergency scene?
Opinions:
Majority - Lansing, Judge
Yes, the ordinary reasonable person standard of care applies because the alleged negligence involved a non-medical function. The court distinguished between tasks requiring professional medical judgment and those within the common knowledge of a layperson. The act of navigating to an address, unlike providing medical treatment, does not require specialized medical training or licensure. The court analogized to cases distinguishing between ordinary negligence and medical malpractice for statute of limitations purposes, where the key factor is whether the conduct required a professional license. Because driving and locating a house are functions that a jury can evaluate based on common experience, the reasonable person standard was appropriate, and expert testimony on a professional standard was not required.
Analysis:
This decision establishes a crucial distinction in negligence law for professionals whose duties involve both specialized and ordinary tasks. It solidifies a functional approach, where the standard of care is determined by the specific act in question rather than the professional's general title. This precedent prevents the expansion of professional malpractice standards to cover all conduct of professionals, thereby clarifying the evidentiary requirements for plaintiffs. In future cases against emergency responders, this ruling will require a clear separation between claims of ordinary negligence (e.g., in driving) and claims of medical malpractice (e.g., in treatment), with only the latter requiring expert testimony on the professional standard of care.
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