Per King v. CompPartners, Inc., et al. 243 Cal.App.4th 685, 80 CCC 10, when a physician-patient relationship exists, either express or implied, as it did between a Utilization Review physician and the injured worker, the patient has a right to expect the physician will care for and treat him or her with proper professional skills and will exercise reasonable and ordinary care toward the patient. Be sure your Utilization Review companies are properly considering this case holding when making determinations regarding care. Note this case has been appealed to the California Supreme Court.