Deborah L. Spicer v. Abimbola…

Summary

The court held that a family physician who refers a patient to a specialist owes no continuing duty for the specialist's subsequent negligent treatment when the referring physician had no further involvement, did not know of any incompetence, and did not act jointly with the specialist. It also held that any negligence preceding the referral was, at most, a remote cause because the specialist independently assumed responsibility for the patient's care. The court therefore affirmed summary judgment for the referring physician.