Ellis v. Peter
This case addresses whether a physician owes a duty of care which extends to a patient's spouse who contracts tuberculosis due to the physician's alleged negligent failure to properly diagnose the disease in the patient. The plaintiffs, John and Joan Ellis, sued Dr. Sebastian A. Peter for medical malpractice. The wife, Joan Ellis, alleged negligence for failure to warn her about her husband's infectious condition. The court held that New York State law does not impose a statutory or common-law duty upon a physician for the benefit of those who may contract such a disease from the patient, as a physician's duty is ordinarily owed to the patient, not the community at large. Therefore, the order was reversed, the plaintiffs' motion to strike defenses was denied, and the defendant's cross-motion to dismiss the wife's second and fourth causes of action was granted.