YALE DIAGNOSTIC RADIOLOGY v. ESTATE OF HURAN FOUNTAIN et al.

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Case Brief and Case Analysis of

Yale Diagnostic Radiology v . Estate of Harun Fountain et al

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Yale Diagnostic Radiology v . Estate of Harun Fountain et al (267 Conn . 351

Facts : The plaintiff in this case is Yale Diagnostic Laboratory , a medical service provider , while the defendants are the estate of Harun Fountain and Vernetta Turner-Tucker , the fiduciary of the estate . Harun Fountain is a minor who was shot in the back of the head by a friend In view of the injuries

he sustained , Fountain needed immediate medical services from different medical services providers . One them is Yale Diagnostic Radiology . Subsequently , plaintiff billed Tucker , Fountain 's mother , the amount of 17 ,694 . Since the debt remained unpaid , Yale Diagnostic d a suit against Tucker . In 1999 , a judgment was obtained against Tucker . This unpaid debt was however discharged pursuant to an of the Bankruptcy court . In the meantime , Tucker d a tort claim against the child who had shot Fountain . Tucker included in her claims substantial sums of money on medical care and equipment ' Both parties agreed to settle and funds were placed in the estate of Fountain . In view of this decision , plaintiff d a claim against Fountain 's estate with the Probate Court . The claim against the estate was denied for the reason that the parties liable for the medical services rendered to a minor are his parents

Procedural History : The Probate court denied the claim against Fountain 's estate holding that the parents of Fountain should be held liable . In view of the denial of the Probate Court , plaintiff appealed to the Superior Court . The trial court reversed the judgment of the Probate Court and allowed the claim . It held that under Connecticut Law minors can be held liable for the payment of their necessaries . It argued that although the parents of the minor child are the one who are primarily liable for the medical bills of their children , under Connecticut Law , the child is secondarily liable for the payment of the same in case his parents fail to pay . Further , the trial court ruled that the child 's estate had already received substantial sum of money as a settlement for the medical services incurred to deny the plaintiff from recovering the same would constitute unjust enrichment

Issue : whether the medical services provider may be able to recover from the child if his parents refuse to make payment or are unable to make their payment

Holding . Yes . The medical services provider may collect from the child in case the parents are unable to pay

Reasoning : It is well-settled that under common-law rule , contracts entered into by a minor child are voidable . This is subject to the exception under the doctrine of necessaries which state that a minor child may not avoid a contract for goods and services that are necessary for his health and sustenance

The doctrine of necessaries has been affirmed by decisions of the Supreme Court and by...