Woods v. District of Columbia
63 A.3d 551
| D.C. | 2013Background
- Woods became ill during a visit to a friend; symptoms included slurred speech, balance loss, and vomiting.
- 911 dispatched a District ambulance; EMTs diagnosed the condition as withdrawal from quitting cigarettes and advised no hospital transport.
- Woods followed the diagnosis and remained at the home overnight, delaying further care.
- The next morning Woods was transported to a hospital and diagnosed with a completed stroke.
- Woods sued the District alleging negligence based on reliance on the misdiagnosis; the trial court dismissed under the public-duty doctrine.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the public-duty doctrine bars Woods’s negligence claim | Woods argues a special relationship existed due to EMS interaction. | District argues no special duty arises from general on-scene EMS care. | Yes; public-duty doctrine bars the claim. |
| Whether EMS misdiagnosis can create a special duty owed to Woods | Woods contends misdiagnosis plus reliance creates a special relationship. | District contends no special relationship arises from misdiagnosis in emergency aid. | No; misdiagnosis does not create a special duty under the doctrine. |
| Whether Woods’s reliance on the EMTs’ diagnosis suffices for justifiable reliance | Woods relied on the EMTs’ on-scene assessment. | Reliance on emergency-care judgment calls generally lacks justifiable basis. | Reliance in this context does not overcome the public-duty doctrine. |
| Whether Johnson/Miller/Warren line of cases foreclose Woods’s theory | Prior cases allow reliance-based liability in some emergency contexts. | Those cases foreclose liability where a special duty isn’t shown. | They foreclose Woods’s theory; doctrine applies. |
Key Cases Cited
- Warren v. District of Columbia, 444 A.2d 1 (D.C. 1981) (establishes two-part special-relationship test and public-duty scope)
- Miller v. District of Columbia, 841 A.2d 1244 (D.C. 2004) (public-duty doctrine bars negligence despite negligent misrepresentation on scene)
- Johnson v. District of Columbia, 580 A.2d 140 (D.C. 1990) (affirmative acts must directly worsen victim’s condition to create liability)
- Allison Gas Turbine Div. of Gen. Motors Corp. v. District of Columbia, 642 A.2d 841 (D.C. 1994) (on-scene emergency acts alone do not create a special duty)
- Wanzer v. District of Columbia, 580 A.2d 128 (D.C. 1990) (one-time 911 contact does not establish a special relationship)