Wickline v. State

Wickline (plaintiff), approved for Medi-Cal-funded surgery and ten days of hospitalization, developed complications requiring a second operation. Her surgeon, Dr. Polonsky, asked Medi-Cal for eight more days beyond the original discharge date because he feared infection; a Medi-Cal physician consultant approved only four extra days, and neither Polonsky nor Dr. Daniels challenged that decision or otherwise acted to keep her hospitalized longer. Wickline was discharged in stable condition but soon developed leg pain, and her leg was amputated nine days later. She sued the State of California (defendant), which ran Medi-Cal; the jury found for her, and the State appealed.

Whether a third-party payor of health care benefits may be held liable when a patient's treating physician makes the actual medical decision to discharge the patient.