Coffee v. McDonnell Douglas Corp.
105 Cal. Rptr. 358, 8 Cal. 3d 551, 503 P.2d 1366 (1972)
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Rule of Law:
An employer who voluntarily undertakes to perform a pre-employment physical examination for a prospective employee assumes a duty to conduct the examination with due care, and can be held directly liable for its own negligence in establishing faulty procedures even if its doctor-employees are found not to be negligent.
Facts:
- In 1966, Robert Coffee applied for a pilot position with McDonnell-Douglas Corporation and was required to undergo a pre-employment physical examination at the company's clinic.
- On July 26, 1966, Dr. Gray, a McDonnell-Douglas employee, examined Coffee, took a blood sample for lab analysis, and gave a provisional medical approval pending the lab results.
- On July 28, 1966, the independent lab sent a blood test report to the McDonnell-Douglas clinic indicating Coffee had an abnormally high sedimentation rate, a sign of a potential inflammatory condition or serious disease.
- Following a corporate procedure established by a prior supervisor, a secretary at the clinic received, time-stamped, and filed the report without any physician ever reviewing or evaluating it.
- Coffee was informed he passed the physical and began working for McDonnell-Douglas on August 9, 1966.
- Seven months later, in March 1967, Coffee collapsed and was diagnosed with multiple myeloma (bone marrow cancer).
- Medical testimony established that the delayed diagnosis allowed the disease to progress, causing more severe injury than if it had been discovered at the time of the examination.
Procedural Posture:
- Robert Coffee sued McDonnell-Douglas Corporation and three of its employee-doctors in a California trial court for negligence.
- The case was tried before a jury.
- The jury returned a verdict in favor of Coffee against McDonnell-Douglas for $200,000, but returned a verdict in favor of the three defendant-doctors, exonerating them.
- The trial court conditionally granted McDonnell-Douglas's motion for a new trial on the grounds of excessive damages.
- Coffee consented to a reduced award of $100,000, and the trial court subsequently denied the motion for a new trial.
- The trial court denied McDonnell-Douglas's motion for a judgment notwithstanding the verdict.
- McDonnell-Douglas (defendant-appellant) appealed the judgment and the denial of its motion for judgment notwithstanding the verdict to the Supreme Court of California.
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Issue:
Is an employer who voluntarily undertakes a pre-employment physical examination for a prospective employee liable for negligently failing to discover a disease, when the employer's own negligent procedures caused the failure, even though its employee-doctors were exonerated of negligence?
Opinions:
Majority - Sullivan, J.
Yes. An employer who voluntarily undertakes to give a prospective employee a physical examination is liable if it performs that examination negligently. The court found that McDonnell-Douglas's liability was not solely dependent on the negligence of its doctors under the doctrine of respondeat superior. Instead, the corporation itself was independently negligent for establishing and maintaining a flawed procedure where critical medical test results could be filed without ever being reviewed by a physician. This corporate negligence was a separate basis for liability. The jury could reasonably conclude that the doctors were not negligent, as they may have properly relied on the corporate procedure to be notified of abnormal results, while concurrently finding the corporation liable for its failure to create a safe and effective procedure for handling those results.
Analysis:
This case is significant for establishing that an employer's duty of care in voluntarily conducting medical examinations can give rise to direct, not just vicarious, liability. It distinguishes corporate negligence (faulty systems and procedures) from the negligence of individual employees. The ruling confirms that an entity can be held liable for its own systemic failures even when the individual agents acting within that system are exonerated. This precedent broadens the scope of corporate liability in situations involving assumed duties, impacting how organizations must design and oversee administrative and medical procedures to ensure due care is exercised at an institutional level.
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