Bateman v. Valley Clinic
127 Wash. App. 1002, 2005 WL 895818 (Wash. Ct. App. 2005)

The plaintiffs are the parents of a healthy child conceived following an unsuccessful vasectomy. In their wrongful birth claim, the plaintiffs cited McKinney v. State, 134 Wn.2d 388, 950 P.2d 461 (1998), a case that recognized a cause of action stemming from an adoption agency's negligent failure to disclose a childŐs FAS diagnosis. The Court found that the McKinney case was inapplicable to the plaintiff's claim, because while damages for the rearing of an unhealthy child (i.e. one with FAS) may be appropriate, such damages are not appropriate with respect to a healthy child.