Shaheen v. Knight
Unknown Reporter Information (1957)
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Rule of Law:
A patient has a cause of action for breach of contract against a physician who agrees to produce a specific result and fails to do so. However, on public policy grounds, a plaintiff cannot recover damages for the financial costs of raising a normal, healthy child born as a result of the breach.
Facts:
- Robert M. Shaheen, a father of four, contracted with Dr. John E. Knight for a sterilization operation.
- Shaheen alleged that Dr. Knight guaranteed the operation would make him "immediately and permanently sterile."
- The operation was performed on September 16, 1954.
- Following the operation, Shaheen and his wife continued their marital relations.
- On February 11, 1956, Shaheen's wife gave birth to their fifth child.
- Shaheen sought the operation for financial reasons, stating he could not afford to support more children and lacked the willpower for other family planning methods.
Procedural Posture:
- Robert M. Shaheen (plaintiff) filed a complaint in assumpsit (contract) against Dr. John E. Knight (defendant) in a Pennsylvania trial court.
- The defendant, Dr. Knight, filed preliminary objections to the complaint, asking the court to dismiss the action.
- The trial court is now ruling on the defendant's preliminary objections.
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Issue:
Does a plaintiff have a valid claim for damages for the cost of raising a normal, healthy child when a physician breaches a special contract to sterilize the plaintiff?
Opinions:
Majority - Williams, P. J.
No. A plaintiff cannot recover damages for the birth of a normal, healthy child following a failed sterilization procedure because allowing such damages is contrary to public policy. While a special contract between a doctor and patient for a particular result is valid and enforceable, the court holds that the birth of a child is a "blessed event" and not a legally cognizable harm. The court reasoned that it is against the "universal public sentiment of the people" to award damages for the life of a child. To do so would mean requiring the physician to pay for the "fun, joy and affection" the plaintiff will have in raising the child, which the court found unacceptable.
Analysis:
This case establishes a critical distinction between the validity of a cause of action and the availability of a remedy. The court affirmed that a doctor can be held to a special contract guaranteeing a result, creating a cause of action separate from malpractice. However, by invoking public policy to deny damages for child-rearing costs, the court severely limited the practical value of such a lawsuit. This decision reflects a strong judicial reluctance to view the birth of a healthy child as a compensable injury, creating a rule where a plaintiff may have a right but no meaningful remedy for the most significant financial consequence of the contract's breach.
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