Science and Law: Hurley v. Eddingfield: What duty does a doctor have to treat patients?

February 22, 2015

Science and Law


Hurley v. Eddingfield
59 N.E. 1058 (Ind. 1901) (Supreme Court of Indiana)

This is an important case from more than a century ago that set an important precedent regarding the boundaries of physician responsibilities. While society generally agrees that we should strive to be good Samaritans, we do not require it of people, nor do we prosecute them for failing to do so. This case asks, should physicians be held to a higher standard than that?

Case Background

  • In 1901, Dr. Eddingfield was a local general practitioner, and the physician for the plaintiff Charlotte Burk and prior to the case.
  • Burk experienced complications during childbirth, and so her husband sent word to Dr. Eddingfield requesting help.
  • Dr. Eddingfield refused to treat Burk for inadequately explained reasons.
  • No other physician was available at the time.
  • The husband was already prepared with payment for the doctor.
  • Charlotte Burk and her newborn died due to the complications.
  • The Burk family brought a wrongful death lawsuit against Dr. Eddingfield

What are the relevant issues?

  • Should law require that doctors treat all patients?
  • To what degree do doctors have freedom of contract?
    • Does this freedom change in emergency situations?
  • Can government or society legally require people to be good Samaritans?
    • Does being a doctor require people to be good Samaritans in certain scenarios? Should a doctor be prosecuted for not trying to save someone who had a heart attack in an airport?
    • What if the emergency appears to beyond the scope of the physician’s training?
  • At what point does the doctor-patient relationship start?
    • The doctor-patient relationship can be viewed as a fiduciary one between a principal and agent, meaning that the doctor accepts a higher level of responsibility for the patient, the client, and must always act in the patient’s best interest. Can the doctor be viewed as a fiduciary agent for the Burk family?
  • Does the fact that Eddingfield was already the family physician mean that he had an obligation to tend to any member of the family in an unmistakable medical emergency?

How was the law interpreted and applied?

  • The court found that Dr. Eddingfield could not be held responsible for the death of Charlotte Burk and her newborn.
  • The fact that he was the family physician did not establish an ongoing fiduciary responsibility to the Burk family.
  • Physicians are not required to enter into fiduciary relationships with clients.
  • From the decision: “In obtaining the state’s license (permission) to practice medicine, the state does not require, and the licensee does not engage, that he will practice at all or on other terms than he may choose to accept.”

Further analysis

This is a case where it is widely acknowledged that morality and legality cannot always be one in the same. In the author’s opinion, Eddingfield acted immorally by refusing to provide medical treatment to Charlotte Burk. However, it seems that while the judge recognized the immorality of the act, he nevertheless did his duty by stating that it was not illegal according to the law.

One major problem in this case is the nebulous nature of the establishment of the doctor-patient relationship. If we were to think of “family physician” as undeniably showing the fiduciary relationship between Dr. Eddingfield and the Burk family, then it is entirely possible that this case could have been ruled in favor of the plaintiff.

States have now widely created incentives for good Samaritan behavior, rather than punishments for failure to do so. For example, we have laws that prevent malpractice lawsuits against off-duty physicians who attempt to help someone in a medical emergency. If they were to try to help, but were not entirely successful due to circumstances beyond their control, they could be sued if not for this legislation, which would create an immense disincentive for physicians to serve the public beyond their legal and professional duty.

While this issue is less concerning 114 years later, since most people have access to emergency services through 911, and most births are attended by physicians, it is still worth considering. How much freedom should physicians have to accept and refuse patients, when they so often can determine whether a person lives or dies?

See: Bioethics and Public Health Law, by Orentlicher, Bobinski, Hall

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About jslachman381

I'm a Yale graduate who majored in History of Science, Medicine, and Public Health.

View all posts by jslachman381


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