In Reynolds v. Decatur Memorial Hospital, 277 Ill. App. 3d 80, 660 N.E.2d 235, 214 Ill. Dec. 44 (1996), the Illinois Appellate Court entertained an appeal from the entry of summary judgment in favor of a physician. According to the appellate court, the sole issue was whether, as a matter of law, a telephone conference between the treating pediatrician ... and Dr. Thomas Fulbright concerning patient's condition created a physician-patient relationship between patient and Fulbright so as to raise a duty which is enforceable in a medical malpractice action in light of the standards of protocol of the hospital at which patient was being treated and in which both physicians were allowed to practice. 277 Ill. App. 3d at 81, 660 N.E.2d at 236. The appellate court affirmed the trial court's finding that no duty existed. The minor plaintiff was injured at home after a fall from a couch and was taken to the emergency room, where he was admitted for observation and further inquiry into his condition. He exhibited an abnormal breathing pattern and tests were conducted to discover a possible infection or other problem. Cervical spine x-rays appeared to be normal. The child was admitted to the hospital and a pediatrician summoned to examine him. That pediatrician contacted a Dr. Fulbright to discuss this case. The latter suggested a spinal tap to determine the involvement, if any, of certain disease processes. The pediatrician did not ask Dr. Fulbright to treat the child, and Dr. Fulbright did not commit to further involvement with his case. Dr. Fulbright later stated that he offered to make himself available if the child's doctor wished. He recalled that he would "often receive inquiries from other doctors asking questions and seeking suggestions." Id. at 83, 660 N.E.2d at 237. The spinal tap was performed the next morning shortly after 3:00 a.m. The pediatrician had wanted to consult again with Dr. Fulbright when she arrived at the hospital later in the morning, but was informed that he was in surgery and unavailable. Dr. Fulbright never received a message that had been posted in the patient's chart the previous evening. The appellate court articulated the standard for determining whether a duty exists: The determination of whether a duty exists - whether the defendant and the plaintiff stood in such a relationship to one another that the law imposed upon the defendant an obligation of reasonable conduct for the benefit of the plaintiff - is an issue of law to be determined by the court. 277 Ill. App. 3d at 84, 660 N.E.2d at 238. The appellate court explained that "a physician's duty is limited to those situations in which a direct physician-patient relationship exists or there is a special relationship." 277 Ill. App. 3d at 85, 660 N.E.2d at 239.