Sadler v. PacifiCare of Nev., Inc.Annotate this Case
Patients of certain healthcare facilities were advised to testify for blood-borne diseases after it was discovered that those healthcare facilities used unsafe injection practices during certain procedures. Plaintiffs, patients of those facilities who had undergone such procedures, filed a complaint on behalf of themselves and a proposed class of similarly situated individuals against PacifiCare of Nevada, Inc., a health maintenance organization, asserting negligence on the ground that PacifiCare failed to establish and implement a quality assurance program to oversee the medical providers within its network. The district court granted PacifiCare’s motion for judgment on the pleadings, concluding that Plaintiffs’ complaint failed to state a negligence claim because they had not alleged an “actual injury,” such as testing positive for a blood-borne illness. The Supreme Court reversed, holding that Plaintiffs’ complaint adequately alleged an injury in the form of exposure to unsafe injection practices that caused a need for ongoing medical monitoring to detect latent diseases that may result from those unsafe practices.