Question:
Plaintiffs Mr. and Mrs. Rye were receiving medical care and family planning services at Women's Care Center of Memphis, MPLLC ("the Clinic"). Mrs. Rye had Rh negative blood, and was expected to receive an injection of RhoGAM from the Clinic during her time of pregnancy. The plaintiffs allege that Mrs. Rye did not receive this injection from her physician at the Clinic, and as a result, she became "Rh-sensitized" meaning that she had "antibodies in her body to Rh-positive blood." The plaintiffs asserted that this incident caused physical injury to Mrs. Rye, disruption of family planning, infliction of emotional distress, and future medical expenses. The plaintiffs filed a complaint alleging medical malpractice against the defendant. The defendants argued that the failure to provide Mrs. Rye with the Rh injection did not cause any harm to the patient or her baby, but did concede that it may disrupt future family planning. The trial court declined summary judgment for plaintiffs' physical injury claim. They granted summary judgment for the plaintiffs' claim of future medical expenses related to future pregnancy. The defendant appealed this decision. How do you think the court ruled on appeal? Why? Rye v. Women's Care Ctr. of Memphis, Tenn. App. LEXIS 131 (2014).