Rachel L. Thomas and Steven N. Thomas, Husband and Wife, Appellants v. Sarah B. Archer and Peacehealth Medical…

Summary

The court affirmed summary judgment against the Thomases on their breach of fiduciary duty and breach of contract claims, holding that the physician's alleged promise to obtain insurance preauthorization was outside the physician-patient fiduciary duty and unsupported by consideration. It reversed summary judgment on promissory estoppel because genuine factual disputes existed concerning reliance, substantial change in position, foreseeability, the existence of an actual promise, and the interests of justice. The attorney's-fee award was vacated and the case remanded for further proceedings.