Montgomery v. Bazaz-Sehgal

Justice SAYLOR,

concurring.

I join the majority in affirming the order of the Superior Court on the basis that expert testimony was not essential to support the causation component, of plaintiffs’ medical battery *591claim seeking damages for mental and emotional injuries. I also agree that the majority has aptly summarized the Court’s existing approach to informed consent claims, which, like those entailing lack of consent, are presently categorized as involving battery rather than negligence. Nevertheless, since the issue under review here involves simple lack of consent to the procedure performed, I would not utilize the appeal as a vehicle to reinforce the battery approach to lack of informed consent. Indeed, there would appear to be good reasons for the Court to select an appropriate case to undertake a reevaluation of the battery paradigm for informed consent, particularly in light of: the weight of authority in other jurisdictions; 1 the arguable incompatibility of the battery theory (and the corresponding concept of touching) with evaluation of informed consent in the context of some medical treatments such radiation therapy and administration of oral medications; the arguable disharmony between intentional tort theory and its associated scienter requirements with informed consent claims; and the discomfort of various appellate jurists with the approach such as is apparent from their opinions.2 Of *592particular significance, the Court has not yet taken the opportunity to consider a series of recent legislative modifications to the informed consent statute,3 which, on their face, appear to incorporate central concepts of negligence theory.

. Most jurisdictions treat lack of informed consent as sounding in negligence. See, e.g., Canterbury v. Spence, 464 F.2d 772 (D.C.Cir. 1972); Dunham v. Wright, 423 F.2d 940 (3d Cir.1970); Mink v. University of Chicago, 460 F.Supp. 713, 716-17 (N.D.Ill.1978);, Cobbs v. Grant, 8 Cal.3d 229, 104 Cal.Rptr. 505, 502 P.2d 1 (1972); Mallett v. Pirkey, 171 Colo. 271, 466 P.2d 466 (1970); Nishi v. Hartwell, 52 Haw. 188, 473 P.2d 116 (1970); Kennis v. Mercy Hosp. Med. Ctr., 491 N.W.2d 161 (Iowa 1992); Natanson v. Kline, 186 Kan. 393, 350 P.2d 1093 (1960); Hodge v. Lafayette General Hosp., 399 So.2d 744, 746 (La.App. 1981); Downer v. Veilleux, 322 A.2d 82 (Me.1974); Sard v. Hardy, 281 Md. 432, 379 A.2d 1014 (1977); Baird v. American Med. Optics, 155 N.J. 54, 713 A.2d 1019 (1998); Watson v. Clutts, 262 N.C. 153, 136 S.E.2d 617 (1964); Winkjer v. Herr, 277 N.W.2d 579 (N.D.1979); Scott v. Bradford, 606 P.2d 554 (Okla.1980); Wilkinson v. Vesey, 110 R.I. 606, 295 A.2d 676 (1972); Wilson v. Scott, 412 S.W.2d 299 (Tex.1967); Mason v. Ellsworth, 3 Wash.App. 298, 474 P.2d 909 (1970); Trogun v. Fruchtman, 58 Wis.2d 569, 207 N.W.2d 297 (1973); Roybal v. Bell, 778 P.2d 108 (Wyo.1989).

. See, e.g., Morgan v. MacPhail, 550 Pa. 202, 211-12, 704 A.2d 617, 622 (1997) (Nigro, J., dissenting); Hoffman v. Brandywine Hospital, 443 Pa.Super. 245, 256, 661 A.2d 397, 402 (1995) (Beck, J., concurring); Stover v. Association of Thoracic and Cardiovascular Surgeons, 431 Pa.Super. 11, 26 n. 6, 635 A.2d 1047, 1054 n. 6 (1993); Wu v. Spence, 413 Pa.Super. 352, 355-57, 605 A.2d 395, 396-97 (1992); Malloy v. *592Shanahan, 280 Pa.Super. 440, 444-50, 421 A.2d 803, 805-08 (1980) (Hoffman, J., dissenting).

. See Medical Care Availability and Reduction of Error (MCARE) Act, Act No. 2002-13, H.B. No. 1802, approved March 20, 2002 (codified as amended at 40 P.S. §§ 1303.101-1303.748 (Supp.2002)); Act of Nov. 26, 1996, P.L. 776, No. 135, § 10 (as amended, 40 P.S. § 1301.811-A) (repealed and recodified as amended at 40 P.S. § 1303.504).