Samantha Ciesielski

Jasa Bulliner
Steven Begando
Tanner Benson

Stowers v Wolodzko
In-Class Case Analysis #1
I.

Procedure
a. Who are the parties?
i. Plaintiff Stowers
ii. Defendants Wolodzko, Smyk, Ardmore Acres
b. Who brought the action?
i. Stowers wife, and mother from Michigan
c.

In what court did the case originate?

i. Local trial court Michigan 119

d. Who won at the trial-court level?

i. Plaintiff
e. What is the appellate history of the case?
i. Wolodzko
II.

Issues
a. What are the relevant facts as recited by this court?
i. Plaintiff, a housewife, in Livonia MI, with her husband and children
ii. She and her husband had been experiencing a great deal of marital
difficulties

iii. She testified that she had informed her husband [that] she was filing for
divorce
iv. Dec. 6 1963, defendant appeared at plaintiffs home
v. Introduced himself as Dr. Wolodzko
vi. Wolodzko had never met either the plaintiff or her husband
vii. [Wolodzko] stated that he had been called by the husband, who had asked
him to examine the plaintiff
viii. Plaintiff testified that defendant told her that he was there to ask about her
husbands back
ix. She testified that she told him to ask her husband and no longer had [a
conversation with either men]
x. [Plaintiff] testified [Wolodzko] never told her he was a psychiatrist
xi. [Wolodzko] stated in his deposition that he told the plaintiff he was there
to examine her
xii. ...[claimed] he could not specifically recollect having told the plaintiff
that he was there to examine her
xiii. Plaintiff subsequently spoke to Dr. Wolodzko at the suggestion of a
policewoman following a domestic quarrel with her husband
xiv. He did inform her he was a psychiatrist
xv. Dec. 30, 1963, Dr. Wolodzko and Dr. Anthony Smyk, at request of
plaintiffs husband, and without authorization knowledge or consent of
plaintiff, signed sworn statement certifying that plaintiff was mentally ill

xvi. Certificate was filed with the Wayne Co. probate court. January 3, 1964
and on the same date the order was entered by probate court for temporary
hospitalization of the plaintiff until a sanity hearing could be held.
xvii. The plaintiff was transported to Admore Acres in January 4, 1964
b. Are there any facts that you would like to know but that are not revealed in the
opinion?
i. Did plaintiff have any previous mental illnesses?
ii. Was the husband home at the time of the evaluation?
iii. Was there ever an actual exam?
iv. Was the defendant a qualified physician?
v. Was there a pre-existing relationship with the doctor and husband?
vi. Pertaining to fact number 14, who did the doctor tell he was a psychiatrist
to? The plaintiff or the policewoman?
vii. Why were the charges of the other defendants dropped?
III.

Issues
a. What are the precise issues being litigated, as stated by the court?
i. Assault
ii. Battery
iii. Malpractice
iv. False imprisonment
b. Do you agree with the way the court has framed those issues?
i. We do not agree that the case against malpractice was dismissed before
trial. It seemed that malpractice would have been applicable to this trial. It

could have added to the sentence, which seemed genuinely deserved. It

was an intentional tort and should have caused the doctor to lose his
license.
IV.

Holding.
a. What is the courts precise holding (decision)?
i. Ardmore Acres and Dr. Smyk were dismissed before trial
ii. Dismissed malpractice before trial
iii. Assault, battery, and false imprisonment went to jury
b. What is its rationale for that decision?
i. False imprisonment Plaintiff was held with no communication allowed
ii. Assault and battery It is possible that the plaintiff was held down and
given medication against her will
iii. Malpractice Wolodzko was cleared due to lack of evidence
c. Do you agree with that rationale?
i. Yes

V.

Implications.
a. What does the case mean for healthcare today?
i. Due diligence must be in effect before trying to imprison people. There
must be a court ordered procedure and usually a second opinion from
another psychiatrist; therefore, false imprisonment is unlikely.
b. What were its implications when the decision was announced?
i. The only implication the doctor was found guilty for was false
imprisonment out of the other three: assault, battery, and malpractice.

c. How should healthcare administrators prepare to deal with these implications?

i. Healthcare administrators should always follow proper procedures and
protocols, such as a psychiatric examination first. Also, ensuring their
psychiatrics are licensed and well practiced physicians; in essence,
policies and regulations should also be followed.
d. What would be different today if the case had been decided differently?
i. There would be false imprisonment and a very corrupt economy lacking
structure, laws, and the concept due diligence would not exist. We would
essentially be imprisoned in a hostile and corrupt society.