Helling v. Carey
Washington Supreme Court · Decided March 14, 1974
Full citation
Helling v. Carey, 519 P.2d 981 (Wash. 1974).
Quote pages are pages of 83 Wash. 2d 514, the official report, so quotes and pinpoints cite it; for 519 P.2d 981, find the page in that reporter.
VerifiedQuotes, pinpoints and citation checked word for word against the opinion; facts checked against the opinion before publication. October 20, 2026.
Barbara Helling
patient with glaucomapetitioner
Thomas F. Carey and Robert C. Laughlin
eye doctorsrespondents
Brief
Facts
Barbara Helling had primary open angle glaucoma, an eye disease in which fluid cannot drain easily from the eye. Pressure inside the eye slowly rises and damages the optic nerve, causing vision loss that usually starts at the edges of sight. The disease usually has few symptoms. Without a pressure test, it is often undetected until the damage is extensive and irreversible. Drs. Carey and Laughlin were partners who practiced ophthalmology (the diagnosis and treatment of eye diseases). Helling first consulted them in 1959 for nearsightedness and was fitted with contact lenses. She returned in September 1963 about irritation from the lenses, and she consulted them many more times through October 1968. Until October 1968, the doctors thought her vision problems came only from the lenses. Then Dr. Carey tested her eye pressure and visual field for the first time. The tests showed glaucoma. She was 32 and had essentially lost her peripheral vision, and her central vision was reduced to about 5 degrees vertical by 10 degrees horizontal. Experts for both sides agreed that the profession's standards did not require routine glaucoma pressure tests for patients under 40, because the disease rarely occurs in that age group. Testimony also indicated that the standards do require the test when a patient's complaints and symptoms suggest glaucoma. Dr. Carey testified that glaucoma under 40 is thought to occur in about one in 25,000 people.
Issue
Does a specialist's compliance with the standard of his profession, which does not require routine glaucoma pressure tests for patients under 40, protect him from liability when a patient under 40 loses much of her vision because the test was not timely given?
Holding
On the undisputed facts of this case, reasonable prudence required timely giving the simple, harmless pressure test to this plaintiff, even though the profession's standard did not require it under age 40. As a matter of law, the doctors were negligent by failing to give it, that negligence proximately resulted in her blindness, and they are liable.
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