healthcare update - issue five


Off the record?


The High Court decision in Loraine v Wirral University Teaching Hospital NHS Foundation Trust came out in May 2008 and was dismissed by many as a first instance decision which did not sit happily with other similar cases. However, it was clear to us when attending a recent obstetric conference that the case is causing widespread concern.

In Loraine, the Judge challenged the safety of the system, often depended upon in Obstetrics and Gynaecology, of relying on the history supplied by a patient’s GP, and the patient herself, when booking her in for the management of pregnancy.

The Judge decided that when Mrs Loraine was booked in for what was her fifth pregnancy, all of the records from her four previous pregnancies should have been to hand and reviewed, so that a complete history could be obtained.

Mrs Loraine had given birth to all four of her previous children at Arrowe Park Hospital and she was there again for the management and birth of her fifth child. The records of all of her previous pregnancies could therefore be retrieved from archive.

The Judge decided that it was not enough, when Mrs Loraine was booked in, for the midwife to retrieve the records from archive only if something of significance came to light. Nor was it enough to be reassured by the fact that Mrs Loraine’s third and fourth deliveries had been uncomplicated.

Had the records been to hand, the Judge accepted Mrs Loraine’s case that a fibroid, which had been detected in her third pregnancy, would have been investigated further, particularly as baby Loraine’s presentation was oblique through to week 37. The Judge also accepted Mrs Loraine’s case that she would therefore have been an in-patient when she went on to suffer placental abruption. Delivery would then have been brought about in a timely fashion, and baby Loraine would have avoided the hypoxic brain injury that befell him, causing cerebral palsy.

The stakes were high, and it seems that the Judge had every sympathy for Mrs Loraine. She could not be relied upon to draw the fibroid to the attention of the midwives and doctors whom she saw and understand that it might present an obstacle to normal delivery. The Judge concluded that the system in place at the Trust of not reviewing previous records was unsafe and so found the Trust liable.

Clearly, this case raises as many questions as it answers in terms of the systems that can and should be put in place, particularly when booking a patient in for the management of pregnancy. Should all of the patient’s hospital records be retrieved and reviewed, to include, say, her orthopaedic records? What if she had given birth previously at a different hospital, why should such a patient be exposed to a potentially unsafe system? How far can anyone rely on the information a patient gives? Even if Loraine can be regarded as a one-off first instance decision it is a salutary lesson as to how vulnerable Trusts can be when anything but the most stringent systems are in place, and an indication that the courts can take a “safe systems” approach, rather than being influenced purely by Bolam.

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Richard Briggs
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The content of this update is provided for the purposes of general interest and information. It contains only brief summaries of aspects of the subject matter and does not provide comprehensive statements of the law. It does not constitute legal advice and does not provide a substitute for it.

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