Joy v. Eastern Maine Medical Center: Extension of a Physician's Duty to Third Parties

In Joy v. Eastern Maine Medical Center, the Maine Supreme Judicial Court, sitting as the Law Court, held that a claimant may sue a physician to recover damages for injuries that were caused by a negligently treated patient. The Law Court focused its analysis on the concept of duty and reasoned that a physician's duty to his patient extends to third parties whose injuries are a foreseeable result of negligent treatment. The Joy case sets forth a broad rule that provides a new and untested means of recovery against physicians and hospitals. This Note examines the new rule against the backdrop of legislative endeavors to stabilize the medical malpractice insurance crisis. In this context, this Note argues that the court's decision is contrary to public policy. This Note also analyzes the Law Court's reasoning and contends that the breadth of the rule announced by the court is unsupported by the case law upon which the court relies. Finally, after reviewing relevant cases and social concerns, this Note suggests an alternative analysis that is consistent both with legal precedent and public policy.