Mills v. Hartford HealthCare Corp.

Syllabus

The plaintiff, the administrator of the estate of the decedent, C, sought to recover damages from the named defendant, H Co., which operates Hartford Hospital, and the defendant physicians, R, B, D, and F, for the allegedly wrongful death of C. In March, 2020, shortly after the onset of the COVID-19 pandemic, C went to the emergency room at a hospital in Norwich complaining of a sore throat and a headache. The emergency room staff suspected that C was experiencing a myocardial infarction. Because the Norwich hospital did not have a cardiac catheterization lab, C was transferred to Hartford Hospital, where such facilities are available. At that hospital, C was examined by R, an interventional cardiologist. H Co., however, had recently modified its protocols due to the pandemic, and patients who were suspected of having COVID- 19 were not to be admitted to the hospital's catheterization lab until they tested negative for COVID-19, unless their physical symptoms dic- tated the need for emergency catheterization. R was concerned that C could have COVID-19 and doubted that she was suffering from a myocar- dial infarction, insofar as he believed that C's symptoms were most consistent with COVID-19 induced myocarditis or myopericarditis rather than a myocardial infarction. Accordingly, R developed a treatment plan pursuant to which C would be tested for COVID-19 and her admission to the catheterization lab would be deferred pending the receipt of a negative COVID-19 test result. A COVID-19 diagnostic test was adminis- tered on March 21, 2020, and, while it was in process over the next several days, B, D, and F became involved in C's care. On March 24, 2020, C's test result came back as negative. F was the only physician responsible for C's care after the receipt of the negative test result. On March 25, 2020, F ordered that C undergo a coronary angiogram in the hospital's catheterization lab, but C died of a myocardial infarction before the procedure was administered. The