Summary
The Supreme Court of Utah affirmed summary judgment for a former psychotherapist in claims for medical malpractice and intentional infliction of emotional distress. The court held that the alleged injuries were insufficient to support medical malpractice, and that any potentially actionable malpractice claim was barred by the statute of limitations. It also held that the alleged emotional distress arising from promises made during an intimate relationship was not sufficiently severe to support an intentional-infliction claim.
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Practice areas
Questions Presented
- Whether the district court complied with Utah Rule of Civil Procedure 52 by providing an adequate written statement of the grounds for granting summary judgment.
- Whether Schuurman's medical-malpractice claim was supported by a legally cognizable injury.
- Whether the medical-malpractice claim was barred by Utah's two-year statute of limitations.
- Whether the continuous negligent treatment rule tolled the statute of limitations.
- Whether the alleged promises of marriage and financial security caused distress sufficiently severe and conduct sufficiently outrageous to support a claim for intentional infliction of emotional distress.
Holdings
- A brief written order satisfies Utah Rule of Civil Procedure 52 when it states the basic essentials of the grounds for granting summary judgment. The district court's order was adequate because it identified the statute-of-limitations basis for the malpractice ruling and the insufficiency of the emotional-distress allegations.
- The alleged destruction of Schuurman's marriage, failure to cure her eating disorder and depression without allegations that the conditions worsened, and generalized pain and suffering unassociated with a specific injury were insufficient to establish the injury element of medical malpractice under the facts alleged.
- The medical-malpractice claim was barred by Utah Code section 78-14-4 because the alleged destruction of Schuurman's marriage was discovered, or should have been discovered, no later than March 1989, more than two years before the action was filed in 1996.
- The continuous negligent treatment rule did not toll the statute of limitations because the alleged treatment during the personal relationship was not causally related to the conditions or injuries for which Schuurman sought recovery.
- The alleged promises of marriage and financial security, and the resulting distress described as comparable to the distress commonly suffered when an intimate relationship fails, did not constitute emotional distress so severe that no reasonable person could be expected to endure it. The claim therefore failed as a matter of law.
Key quotations
“To comply, the court need only include the basic essentials of the grounds upon which it relies.” (¶ 8)
“To make out a cause of action for medical malpractice, the plaintiff must allege, and eventually prove, (1) the standard of care by which the doctor's conduct is to be measured, (2) breach of that standard by the doctor, and (3) injury (4) proximately caused by the doctor's negligence.” (¶ 10)
“The law intervenes only where the distress inflicted is so severe that no reasonable [person] could be expected to endure it” (¶ 23)
Factual background
Schuurman received thirty-four formal psychotherapy sessions from Shingleton between June 1988 and February 1989 for depression and an eating disorder. Shortly after formal therapy ended, they began a sexual and personal relationship that lasted until June 1995. Schuurman alleged that Shingleton mishandled transference, continued negligent treatment through a dual relationship, and made false promises of marriage and financial security that caused emotional distress and contributed to the destruction of her marriage and failure to obtain further treatment.
Procedural history
Schuurman sued her former psychotherapist, Shingleton, alleging medical malpractice and intentional infliction of emotional distress arising from their therapist-patient and subsequent personal relationship. The district court granted Shingleton's motion for summary judgment, holding that the medical-malpractice claim was barred by the statute of limitations and that the emotional-distress claim failed as a matter of law. The Utah Supreme Court affirmed.