In Clough v. Lively (1989), 193 Ga. App. 286, 387 S.E.2d 573, the decedent was arrested and brought to the defendant-hospital for a blood sample to be drawn to determine whether the decedent had been operating a motor vehicle while under the influence of alcohol or drugs. While at the hospital, the decedent declined any treatment. After leaving, the decedent expired and suit was filed. The court determined that merely drawing blood pursuant to an arresting officer's request does not give rise to a consensual relationship between the patient and the hospital. In other words, a patient must actively seek services from the hospital to give rise to a hospital-patient relationship. Because the court found no such relationship came into existence, it determined the hospital could not be independently liable.