No. The insurance company does not have to cover the lawsuit. The insurance policy was very clear that it only covered lawsuits about injuries 'to a patient.' Mr. Brewer, the man who sued Dr. Hayne, was never his patient; the murder victim was. Since the words in the contract were not confusing, the court had to follow them exactly as they were written. It's the doctor's responsibility to read his insurance policy and understand what it does and does not cover.

No, Dr. Hayne's medical malpractice insurance does not cover lawsuits against him by wrongly convicted people who were not his patients. The insurance policy very clearly says it only covers lawsuits claiming Dr. Hayne hurt his own patients. Mr. Brewer was never Dr. Hayne's patient and is suing for harm to himself, not a patient. Dr. Hayne is expected to know what his own insurance policy says. Even if the insurance company told him something different before, what the written policy actually says is what matters. Dr. Hayne had a long time to notice his policy didn't cover everything he wanted and to get extra coverage.

No, we hold that Dr. Hayne's medical malpractice insurance does not cover lawsuits against him by wrongly convicted people who were not his patients. The insurance policy clearly states it only covers lawsuits alleging harm to his own patients. Mr. Brewer was never his patient and is suing for harm to himself, not as a patient. An insured is expected to know and understand their own insurance policy. Even if the insurance company told him differently before, what the written policy actually says is what matters. Dr. Hayne had ample time to notice his policy did not cover everything he wanted and to acquire extra coverage.

No. A medical malpractice insurance policy that unambiguously limits coverage to claims for injuries 'to a patient' does not cover a lawsuit by an exonerated non-patient criminal defendant. The court's analysis begins and ends with the plain language of the insurance policy, which is a contract. The policy at issue defines a covered 'claim' as a lawsuit alleging 'injury, disability, sickness, disease, or death to a patient arising from [the insured’s] rendering or failing to render professional services.' Brewer, the party suing Hayne, was never Hayne's patient and does not claim to have been. Therefore, under the unambiguous terms of the contract, the claim is not covered. An insured is charged with knowledge of the terms of their own policy, and any alleged prior oral representations cannot vary the clear terms of the written contract under the parol evidence rule.

No, Dr. Hayne's medical malpractice insurance policy does not cover claims made against him by exonerated criminal defendants for injuries to themselves due to his negligence. The policy language unambiguously provides coverage only for claims alleging injury to Hayne's patients. Brewer was never Hayne's patient and alleges injuries only to himself. Knowledge of the clear and unambiguous terms of the policy is imputed to Hayne. Even if a representative of The Doctors had informed Hayne that the policy would cover him for this type of lawsuit, the plain language of the policy must control over any prior oral agreements. Hayne had ample time to recognize and remedy any deficit in his coverage.

Steven Hayne v. The Doctors Company

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