Lawrence v. Ingham County Health Department Family Planning/Pre-Natal Clinic

Michigan Court of Appeals
408 N.W.2d 461 (1987)

ELI5:

Rule of Law:

A patient's promise to follow a doctor's medical advice is not a legally enforceable promise and therefore does not constitute sufficient consideration to form an implied contract for medical services.

Facts:

On December 13, 1979, Ethel Lawrence visited the Ingham County Health Department Family Planning/Pre-Natal Clinic and tested positive for pregnancy.
Lawrence continued to receive routine prenatal treatment from the clinic.
The clinic agreed to provide medical services to Lawrence, and she allegedly agreed to follow the directions of the clinic's physicians and medical personnel for the benefit of her unborn child.
On August 19, 1980, Lawrence went into labor and underwent an emergency Caesarean section.
Her daughter, Jessica Lawrence, suffered fetal distress and prenatal asphyxia during birth.
As a result, Jessica Lawrence sustained permanent, serious brain damage.

Procedural Posture:

Plaintiffs Ethel and Douglas Lawrence filed a complaint against the Ingham County Health Department Family Planning/Pre-Natal Clinic and others in a Michigan trial court.
The trial court granted summary disposition to the clinic on the plaintiffs' negligence claims on the basis of governmental immunity.
Plaintiffs filed a third amended complaint, alleging two counts of breach of contract against the clinic.
The clinic filed a motion for summary disposition on the contract claims, arguing failure to state a claim upon which relief could be granted (MCR 2.116(C)(8)).
The trial court granted the clinic's motion, concluding that the plaintiffs failed to plead adequate consideration to support a contract claim.
Plaintiffs (appellants) appealed the trial court's grant of summary disposition to the Michigan Court of Appeals.

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Issue:

Does a patient's promise to follow the medical advice of a clinic's staff constitute legally sufficient consideration to form an implied contract for prenatal care?

Opinions:

Majority - M. J. Kelly, P.J.

No. A patient's promise to follow a medical provider's advice is not legally enforceable and therefore lacks the value necessary to serve as consideration for an implied contract. For a promise to serve as consideration, it must be of some value to the promisor, which in this context means it must be legally enforceable. The court reasoned that the defendant clinic would have no cause of action for breach of contract against Ethel Lawrence if she failed to follow its medical advice. This lack of mutuality of obligation means her promise cannot be deemed consideration. The court distinguished this situation from cases where consideration was provided in the form of payment for services, which is a tangible and enforceable obligation.

Dissenting - Sawyer, J.

Yes. A patient's promise to do something they are not legally obligated to do, such as following a physician's advice, constitutes legal detriment and can be sufficient consideration to support a contract. The dissent argues that it is not the role of the court to scrutinize the adequacy of consideration, which is a question for the factfinder. A person can contractually obligate themselves to follow medical advice, and whether such an agreement was actually formed in this case is a factual question that should not be dismissed at the pleading stage. The majority improperly concludes that the promise is unenforceable as a matter of law, confusing the novelty of the claim with its legal impossibility, thereby denying the plaintiffs their day in court.

Analysis:

This decision reinforces the distinction between medical malpractice (tort) and breach of contract claims, particularly in cases involving governmental immunity. By holding that a patient's promise of compliance is not adequate consideration, the court limits the ability of plaintiffs to reframe malpractice claims as contract claims to circumvent immunity defenses. The ruling establishes that for a contract claim to succeed in a medical context, the consideration from the patient must be a legally enforceable obligation, such as payment for services, rather than an intangible promise of cooperation. This precedent makes it significantly more difficult to establish an implied contract for a specific standard of care based solely on the doctor-patient relationship.

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