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Keywords

lawsuitnegligenceappealtrialcomplianceregulation

plaintiffdefendantnegligenceappealtrialcomplianceregulation

Related Cases

United Blood Services, a Div. of Blood Systems, Inc. v. Quintana, 827 P.2d 509, 60 USLW 2610

Facts

United Blood Services (UBS) is a non-profit blood bank that processes blood from volunteer donors. In April 1983, UBS received a blood donation that was later found to be contaminated with the AIDS virus. Mrs. Quintana received this contaminated blood during emergency surgery for a gunshot wound in May 1983. She tested positive for the AIDS virus a year later, leading to the negligence lawsuit against UBS, which claimed that UBS failed to properly screen the blood donor and the donated blood.

UBS is a non-profit blood banking division of Blood Systems, Inc., and operates blood centers throughout the western United States. In procuring whole blood, UBS relies strictly on volunteer donors and then processes the blood in the form of whole blood or blood components, such as red blood cells, platelets, and fresh frozen plasma, and supplies the blood or blood components to hospitals.

Issue

Did the trial court err in applying a professional standard of care to United Blood Services' actions in procuring and processing blood, rather than an ordinary negligence standard?

Rule

The court held that the professional standard of care is imposed upon blood banks in procuring and processing human blood, but it should not be considered conclusive proof of due care.

the professional standard of care is imposed upon blood banks in procuring and processing human blood for use in subsequent transfusion during medical treatment, but … that standard should not have been considered as conclusive proof of due care on the part of blood bank.

Analysis

The court analyzed the evidence presented and determined that the trial court's application of a professional standard of care was inappropriate. Instead, the court concluded that UBS's actions should be evaluated based on what a reasonable and prudent blood bank would have done under similar circumstances, taking into account compliance with governmental regulations and industry practices as merely evidence of reasonable care.

the court of appeals reasoned that UBS's conduct “should be measured against what a reasonable and prudent blood bank would or should have done under the same or similar circumstances” and that, under that standard of ordinary care, compliance with governmental regulations and industrial customs and practices would merely constitute evidence of reasonable care and would not be conclusive proof on that issue.

Conclusion

The Supreme Court affirmed the Court of Appeals' decision, granting the Quintanas a new trial based on the improper application of the professional standard of care by the trial court.

We conclude, as did the court of appeals, that the Quintanas must be granted a new trial, but we do so for reasons different from those relied upon by the court of appeals.

Who won?

The Quintanas prevailed in the appeal because the court found that the trial court had erred in its application of the professional standard of care, which should not have been considered conclusive proof of UBS's due care.

the court found that the trial court erred in applying the professional medical standard of care to defendant's acts, by precluding plaintiffs from presenting evidence which might tend to show that the customs and practices in the defendant's industry might not be reasonable and prudent.

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