Kawaauhau v. Geiger
Headline: Court allows doctors to discharge malpractice debts from negligent or reckless care, ruling only intentional harm prevents debt cancellation in bankruptcy and affecting unpaid malpractice awards.
Holding: The Court held that a debt from medical malpractice based on negligent or reckless care is dischargeable because the bankruptcy-law exception covers only debts for injuries the debtor intended, not unintended harms.
- Malpractice debts from negligence or recklessness can be wiped out in bankruptcy.
- May reduce plaintiffs’ ability to collect from bankrupt doctors after negligent care.
Summary
Background
A patient, Margaret Kawaauhau, was treated by a doctor, Dr. Paul Geiger, for a foot infection. The doctor prescribed oral rather than intravenous penicillin, left on a trip, canceled a transfer to a specialist, and stopped antibiotics. The patient’s foot worsened and she lost her leg below the knee. A jury awarded the patient and her husband about $355,000. The doctor carried no malpractice insurance, moved, and then filed for bankruptcy while the patients sought to stop the debt from being wiped out.
Reasoning
The Court addressed whether the bankruptcy rule barring discharge applies to injuries caused by negligent or reckless acts or only to injuries the debtor intended. The Court read the statute’s phrase “willful and malicious injury” to require an actual intent to cause harm, not merely an intentional act that accidentally caused injury. The opinion explained that the statute tracks traditional intentional torts and that expanding the rule to cover negligent or reckless conduct would sweep in many unintended harms and overlap other statutes. The Court limited older cases cited by the patients and affirmed the appeals court’s narrower reading.
Real world impact
Under this decision, money judgments from malpractice based on negligence or recklessness can generally be discharged in bankruptcy, meaning bankrupt doctors may be able to avoid paying those debts. The ruling leaves it to Congress to change the rule if lawmakers want malpractice debts treated differently. It also resolves differing lower-court views and clarifies when a debt survives bankruptcy.
Dissents or concurrances
The opinion notes lower courts were split: some circuits had treated similar malpractice judgments as nondischargeable, but the Court sided with the view that only intentional injuries are excepted from discharge.
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