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Illinois Supreme Court Rules Doctors Owed no Duty to Nonpatient

A recent Illinois Supreme Court ruling is a victory for patient-physician confidentiality and protects doctors from unwarranted liability exposure, according to physicians.

On Sept. 24, the Illinois Supreme Court ruled that a group of physicians and other health care professionals did not have a duty to prevent the murder of the wife of a mentally ill patient they treated.


Richard Street sought psychiatric treatment at Community Resource Center Inc. in 2003 after he reported thoughts that his wife was trying to poison him, court records said. Street told the doctors and hospital social workers caring for him that he planned to kill his wife, Teresa Street, and that he wanted to be admitted to a psychiatric facility. He changed his mind during the admitting process and returned home, while continuing his medication treatment.

Three days later, Richard Street was found lying over the body of his strangled wife. He ultimately pleaded guilty to murder and was sentenced to 18 years in prison, records show.

Teresa Street’s family sued the hospital, several physicians and other health care workers for wrongful death, alleging that they had failed to treat her husband properly and failed to warn his wife of his potentially violent tendencies.

But the Supreme Court unanimously concluded that the doctors and others owed no duty to Teresa Street, since she was not their patient.

Justices recognized that doctors may have a responsibility to third parties in limited circumstances involving a “special, intimate relationship,” typically between a mother and a fetus. But a marital relationship, as in this case, did not qualify to allow third parties to transfer doctors’ duty of care outside a direct patient-physician relationship, the court said.

Physicians expressed concern that if the case had gone the other way, the decision could have jeopardized the privacy of mental health patients’ sensitive information and ultimately their care.

State law gives doctors leeway to share patient information voluntarily with family members or law enforcement if physicians believe, in their medical judgment, that such disclosures are appropriate. But they are not mandatory, and doctors make those decisions for the benefit of their patients, not third parties.

If you or a family member has been injured because of the fault of someone else; by negligence, personal injury, slip and fall, car accident, medical malpractice, trucking accident, drunk driving, dangerous drugs, bad product, toxic injury etc then please contact the Fort Worth Texas Medical Malpractice Attorney Dr. Shezad Malik. For a no obligation, free case analysis, please call 817-255-4001 or Contact Me Online.

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