Jane Doe v. Charles Cochran

Summary

The court held that a physician may owe a common-law duty of care to an identifiable, exclusive sexual partner of a patient when the physician negligently misreports a positive STD test obtained for that partner's protection. The alleged conduct constituted ordinary negligence rather than medical malpractice because accurately reading and communicating the test result did not require specialized medical judgment or expert testimony. The court therefore reversed the order striking the complaint and remanded for further proceedings.