Stowers v. Wolodzko 386 Mich. 119, 191 N.W.

2d 355(1971)

I.

Procedure. a. Who are the parties? The parties involved in this case are Ms. Stowers a housewife in Michigan with martial issue who intended to file for divorce. Dr. Wolodzko a psychiatrist that had Ms. Stowers committed, Anthony Smyk and Admore Acres a private mental health hospital. (Anthony Smyk and Admore Acres were dismissed). b. Who brought the action? Ms. Stowers originated the complaint c. In what court did the case originate? The case started at the trial court level. It began at the Wayne County Probate Court in Michigan. d. Who won at the trial-court level? Dr. Wolodzko originally won at the trial court level because he had achieved getting Ms. Stowers committed. When Ms. Stowers brought up action there were three complaints being Malpractice, False Imprisonment and Assault and Battery. The courts found in favor of Dr. Wolodzko on the count of Malpractice. The courts found in favor of Ms. Stowers on the complaints of False Imprisonment and Assault and Battery. Malpractice Dr. Wolodzko Won False Imprisonment Found in favor of Ms. Stowers Assault and Battery Found in favor of Ms. Stowers e. What is the appellate history of the case? Dr. Wolodzko appealed the case, but the appellate court affirmed the original courts decision.

II.

Facts. a. What are the relevant facts as recited by this court? 1. Stowers is a housewife. 2. Stowers is a resident of Livonia, Michigan. 3. Stowers lives with her husband, and children. 4. Stowers intended to divorce her husband. 5. On December 6, 1963, Dr. Wolodzko appeared at plaintiffs home. 6. Dr. Wolodzko introduced himself as Dr. Wolodzko. 7. Dr. Wolodzko had never met either plaintiff or her husband before he came to the house. 8. Dr. Wolodzko stated he had been called by the husband, to examine plaintiff. 9. Plaintiff testified that defendant told her that he was there to ask about her husbands back. 10. Stowers testified that she told him to ask her husband, and they had no further conversation. 11. Stowers testified that he never told her that he was a psychiatrist. 12. Dr. Wolodzko stated in his deposition, that he told plaintiff he was there to examine her. 13. Dr. Wolodzko stated that he could not specifically recollect having told plaintiff that he was there to examine her.

14. Dr. Wolodzko stated in his deposition that he was sure that the fact he was a psychiatrist would have come out, but that he couldnt remember if he had told plaintiff that he was a psychiatrist. 15. Stowers subsequently spoke to Dr. Wolodzko at the suggestion of a Livonia policewoman, following a domestic quarrel with her husband. 16. Dr. Wolodzko did inform her at that time that he was a psychiatrist. 17. On December 30, 1963, Dr. Wolodzko and Dr. Anthony Smyk, apparently at the request of plaintiffs husband and without the authorization, knowledge, or consent of plaintiff, signed a sworn statement certifying that they had examined Stowers, and found her mentally ill. 18. Certificate was filed with the Wayne County Probate Court on January 3, 1964. 19. On January 3, 1964, an order was entered by the probate court for the temporary hospitalization of plaintiff until a sanity hearing could be held. 20. The Judge ordered Stowers committed to Ardmoore Acres, a privately operated institution, pursuant to the provisions of Michigan law. 21. Stowers was transported to Ardmore Acres on January 4, 1964. 22. Dr. Wolodzko requested permission to treat the plaintiff on several different occasions, and Stowers refused. 23. For six days, Stowers was placed in the security room. 24. The security room was a bare room except for the bed. 25. The windows in the security room were covered with wire mesh. 26. During five of the six days, Stowers refused to eat, and at all times refused medication. 27. Dr. Wolodzko telephoned orders to the hospital and prescribed certain medication. 28. Dr. Wolodzko visited her often during her stay. 29. When Stowers arrived at the hospital she was refused permission to receive or place telephone calls, or to receive or write letters. 30. Dr. Wolodzko conceded at the trial that plaintiff wished to contact her brother in Texas by telephone and that he forbade her to do so. After nine days, she was allowed to call her family but no one else. b. Are there any facts that you would like to know but that are not revealed in the opinion? I would just like to know a little more background on the case. I dont fully understand how Stowers could have been committed especially on the false pretenses she was given. III. Issues. a. What are the precise issues being litigated, as stated by the court? False imprisonment Assult and Battery Malpractice b. Do you agree with the way the court has framed those issues? I believe that there should be some changes in the way that the court has framed some of these issues. Was the psych test should have been done before being institutionalized? Was her medical chart examined. Was there an expert testimony. Did she divorce her husband? Did Stowers see Dr. Wolodzko with or without her husband there? Did Dr. Wolodozko or Dr. Smyth have a personal relationship with her husband?

Holding. a. What is the courts precise holding (decision)? False Imprisonment: Defendant Dr. Wolodzko found guilty. Assault and Battery: Defendant Dr. Wolodzko found guilty. Malpractice: Defendant Dr. Wolodzko not guilty b. What is its rationale for that decision? False Imprisonment: Plaintiff was held incommunicado Assault and Battery: It is possible that the plaintiff was held down, and forced medication. Malpractice: Dr. Wolodzko lied as to who, and why he was there to examine. c. Do you agree with that rationale? I agree with the False Imprisonment rationale, and also the Assault and Battery rationale. I do not believe in the Malpractive rationale. Dr. Wolodzko should have not lied to Stowers about who he was, or why he was in her home.

IV.

V.

Implications. a. What does the case mean for healthcare today?

This case helps with todays healthcare because it teaches, physicians that they need to be careful with how they treat patients. Physicians are not allowed to state whoever they think they can be, and get away with their actions. Physicians today are held to a higher standard, because they cannot lie about who they are, show up unexpectedly, or put a patient into a hospital without having a medical chart examined. With this case, the healthcare field is a safer place for all patients, whether they are sane or insane.
b. What were its implications when the decision was announced?

When the decision was announced the implications, were to help protect the patient, and future patients. No patient should ever be falsely imprisoned. Healthcare is meant to keep people healthy, and happy, not to hinder patients
c.

How should healthcare administrators prepare to deal with these implications?

Health care administrators need to be prepared to deal with these implications. In todays world we do not see many patients being put into mental hospitals, without a proper examination, but we do need to be aware that it can happen. Healthcare administrators need to make sure that their physicians are following rules, and regulations.
d. What would be different today if the case had been decided differently?

If this case was decided differently, then we would have much different laws today. A patient would be allowed to be held down for their medication. Any person would be allowed to be confined to a hospital, just because a doctor says so. That patient who would be confined to a hospital would not have the right to call, or write anyone outside of the hospital.