Jensen v. Intermountain Health Care Inc. Case Brief: Medical Malpractice and the Importance of Informed Consent in Utah

Case Brief: Jensen v. Intermountain Health Care Inc.

Court: Supreme Court of Utah
Citation: Jensen v. Intermountain Health Care, Inc., 2004 UT 76, 100 P.3d 616
Decided: August 30, 2004

Facts

In Jensen v. Intermountain Health Care, Inc., the plaintiff, Richard Jensen, underwent a laparoscopic cholecystectomy at an Intermountain Health Care facility. During the surgery, Jensen's bile duct was unintentionally severed, leading to severe complications and subsequent medical treatment, including additional surgeries and significant health challenges. Jensen and his wife filed a lawsuit against Intermountain Health Care, alleging medical malpractice, including negligence in the surgical procedure and improper postoperative care.

The plaintiffs argued that the surgical team failed to follow established standards of care, which led to the severing of the bile duct and resulted in further injury and damages. Intermountain Health Care contended that the standard of care was met and that the complications were an acceptable risk of the procedure.

Issues

1. Medical Malpractice: Did Intermountain Health Care and its employees breach the standard of care during Jensen's surgery?
2. Informed Consent: Was Jensen properly informed of the risks associated with the procedure, including the potential for injury to the bile duct?
3. Liability and Damages: What amount of damages should be awarded for Jensen’s injuries?

Holding

The Supreme Court of Utah affirmed the trial court's decision to allow the jury to determine whether Intermountain Health Care was liable for medical malpractice. The jury found in favor of Jensen, awarding him damages for his medical expenses, pain and suffering, and loss of enjoyment of life.

Reasoning

1. Standard of Care: The court noted that medical professionals are required to adhere to the accepted standards of practice in their field. Expert testimony presented at trial indicated that the surgical team had deviated from established practices during Jensen’s surgery, contributing to the injury.

2. Informed Consent: The court ruled that a physician must disclose risks associated with a procedure to obtain informed consent. The jury considered whether Jensen had been adequately informed of the risks, including the risk of bile duct injury, prior to undergoing surgery. Testimony revealed that Jensen was not adequately informed about the severity and likelihood of such a risk.

3. Liability: The court concluded that the jury could reasonably find Intermountain Health Care liable for Jensen's injuries based on the evidence presented, which demonstrated a breach of the standard of care in both the surgery and the informed consent process.

4. Damages: The jury awarded Jensen $1.2 million in damages, broken down into specific categories: $500,000 for medical expenses, $400,000 for pain and suffering, and $300,000 for loss of enjoyment of life. The court upheld this award, finding it consistent with the evidence of Jensen’s suffering and medical costs resulting from the negligence.

Conclusion

The case of Jensen v. Intermountain Health Care Inc. highlights critical aspects of medical malpractice, particularly the necessity for physicians to meet the standard of care and the importance of obtaining informed consent from patients. The decision affirmed that patients are entitled to compensation for injuries resulting from a failure to adhere to these legal and ethical obligations.

List of Cases Cited

• Hoffman v. Board of Education, 2003 UT 37, 76 P.3d 183 - Discusses the importance of adhering to the standard of care and implications of negligence.
• Alberts v. Mardian, 792 P.2d 184 (Utah 1990) - Addresses the issues surrounding informed consent in medical procedures.
• Bishop v. United States, 568 P.2d 1093 (Utah 1977) - Explores the general principles of liability in medical malpractice cases.

Similar Cases

• Gorham v. St. Marks Hospital, 1999 UT 47, 979 P.2d 1051 - Involves issues of negligence during surgical procedures and the duty of care owed to patients.
• Kirkland v. D’Anjou, 840 P.2d 314 (Utah App. 1992) - Discusses the application of the standard of care in a medical setting and the consequences of failing to meet it.
• Evers v. South West Utah Health Care, 2002 UT 49, 48 P.3d 928 - Addresses informed consent and the requirement for doctors to disclose relevant risks to patients.