Supreme Court of Rhode Island

Heather Blouin v. Divya Koster, M.D.

August 20, 2024

Summary

The Rhode Island Supreme Court affirmed the Superior Court’s grant of summary judgment to the pediatric and obstetric defendants, holding that the pediatric defendants owed no legally cognizable duty to the plaintiff‑parents and that the Court’s prior decision in Ho‑Rath III bars the wrongful‑life claims of X.B. and D.B. The Court reached these conclusions by applying the Banks five‑factor test and finding the policy and burden considerations outweigh any foreseeability of harm.