A negligence action was brought by a mother on behalf of her minor daughter against a hospital. It alleged that when the mother was 13 years of age, the hospital negligently transfused her with Rh-positive blood. The mother’s Rh-negative blood was incompatible with and sensitized by the Rh-positive blood. The mother discovered her condition eight years later during a routine blood screening ordered by her physician in the course of prenatal care. The resulting sensitization of the mother’s blood allegedly caused damage to the fetus, resulting in physical defects and premature birth. Did a patient relationship with the transfusing hospital exist?
