White v. Harris

Fourteen-year-old Krystine White participated in a one-time, 90-minute telepsychiatry research video session with Dr. Harris (defendant), an employee of Fletcher Allen Health Care (defendant), after which Harris completed a written assessment describing her illness, his diagnostic impressions, and a proposed treatment plan, which he shared with her regular treating physicians; he provided no further follow-up care or medication. After Krystine later died by suicide, her father (plaintiff) sued for wrongful death, alleging Harris's treatment fell below the standard of care; Harris and the hospital argued no doctor-patient relationship existed, and the trial court granted them summary judgment.

Whether a 90-minute telepsychiatry video consultation, followed by a written consultation assessment and proposed treatment plan, is sufficient to create a doctor-patient relationship and duty of care.