Renslow v. Mennonite Hospital

Emma Renslow (plaintiff), who had Rh-negative blood, received two Rh-positive blood transfusions from Mennonite Hospital (defendant) at age 13. She suffered no immediate physical reaction, but the transfusions sensitized her blood. Eight years later, while pregnant, she learned of the sensitization, which endangered her fetus and forced her to deliver prematurely; her daughter, Leah, suffered brain damage and other organ damage as a result. Renslow sued the hospital for negligence individually and on Leah's behalf. The trial court dismissed the suit, reasoning the hospital owed no duty to Leah because Leah wasn't even conceived at the time of the transfusions; the appellate court reversed, finding the harm to a future child was reasonably foreseeable, and the hospital appealed.