## Facts

- Barbara Helling repeatedly consulted two ophthalmologists between 1959 and 1968 for myopia and later contact-lens irritation.
- The doctors did not perform glaucoma-related testing (including an intraocular pressure test) during those years.
- In October 1968, when Helling was 32, testing revealed primary open-angle glaucoma and substantial, largely irreversible visual loss, including severe loss of peripheral vision and markedly constricted central vision.
- Helling sued for medical malpractice, alleging the doctors’ failure to timely test for and diagnose glaucoma caused severe and permanent injury.
- Expert testimony for both sides stated that the professional practice in ophthalmology at the time did not call for routine glaucoma pressure testing of patients under 40 because glaucoma was rare in that group.
- The trial court entered judgment for the defendants, and the intermediate appellate court affirmed.

## Issues

1. Whether physicians may be found negligent for failing to administer a simple, low-risk diagnostic test when they complied with the uniform professional custom that did not require the test for the patient’s age group.
2. Whether the court may set the legal standard of care above prevailing medical practice based on reasonable prudence and risk–burden considerations.

## Decision

- The Washington Supreme Court reversed and held the defendants negligent as a matter of law.
- The court concluded that reasonable prudence required timely administration of an intraocular pressure test, notwithstanding professional custom.
- The court emphasized the test’s minimal burden (simple, inexpensive, harmless) compared to the grave risk of undetected glaucoma and resulting blindness.

## Legal Principles

- Professional custom is relevant evidence of due care in malpractice cases but is not conclusive of the legal standard of care.
- Courts may require precautions beyond uniform professional practice when reasonable prudence indicates that additional steps are warranted.
- A low-probability risk may still require preventive action when the potential harm is severe and the precaution is minimal in cost and risk.
- Where the facts establish breach under the court-defined duty, negligence may be determined as a matter of law rather than left to the factfinder.

## Conclusion

The court imposed liability for failure to administer a simple glaucoma pressure test, holding that reasonable prudence can require more than prevailing medical custom when an inexpensive, harmless measure can reduce the risk of catastrophic injury.


Helling v. Carey, 83 Wn.2d 514, 519 P.2d 981 (Wash. 1974)