HomeMy WebLinkAbout97-857 civilJOHN M. STONE and JOYCE V. : IN THE COURT OF COMMON PLEAS OF
STONE, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs :
:
v. NO. 97-857 CIVIL
:
CARLISLE HOSPITAL AND :
HEALTH SERVICES, :
Defendant :
IN RE: DEFENDANT'S MOTION FOR SUMMARY JUDGMENT
Before HOFFER, P.J. and OLER, J.
~ ORDER OF COURT
AND NOW, ~'~ ~ ~, I(~?~, pursuant tothe oPinion filed this
date, and after hearing oral argument, Defendant's Motion for Summary Judgment
is denied.
By the Court,
P.J.
Wayne F. Shade, Esquire
53 West Pomfret Street
Carlisle, PA 17013
For the Plaintiffs
Francis E. Marshall, Jr., Esquire
Marshall, Smith & Haddick, P.C.
20 South 36th Street
Camp Hill, PA 17011
For the Defendant
JOHN M. STONE and JOYCE V. : IN THE COURT OF COMMON PLEAS OF
STONE, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
:
v. : NO 97-857 CIVIL TERM
:
CARLISLE HOSPITAL AND :
HEALTH SERVICES, :
Defendant :
IN RE: DEFENDANT'S MOTION FOR SUMMARY JUDGMENT
Before HOFFER, P.J. and OLER, J.
OPINION
HOFFER, P.J.:
In this opinion, we address Defendant's motion for summar~ judgment. The
facts of this case are as follows: Plaintiff, ,John M. Stone, was admitted to Carlisle
Hospital, Defendant, on August 21, 1996, suffering from cirrhosis of the liver.
Throughout the evening of August 21, 1996, Stone's mental state deteriorated,
caused by toxins produced by his diseased liver. Plaintiff was permitted to walk
the halls of the medical ward where nurses monitored him. Early in the morning
of August 22, 1996, Stone opened the second floor lounge window and climbed
out onto the first floor roof of the hospital. A nurse tried, but was unable, to
restrain him. Stone sustained cuts and lacerations, including a six centimeter
wound that required stitches. The wounds were treated in the emergency room
and Stone was sent to the psychiatric ward. Stone remained in the psychiatric
ward until August 28, 1996, and was ultimately discharged from the hospital on
August 30, 1996.
97-857 CIVIL TERM
Plaintiffs filed suit on February 20, 1997, asserting that Defendant was
negligent in its care of Stone. Throughout the discovery process, Plaintiffs have
never provided Defendant with a medical expert report. Plaintiffs' attorney appears
to have taken the position that expert opinion testimony is not required because the
negligence in this case is so clear that a lay person can comprehend it without the
aid of expert opinion. Defendant has filed this motion for summary judgment
contending that Plaintiffs must provide expert medical testimony to present a prima
facie case of malpractice. Without expert testimony, Defendant claims it is entitled
to summary judgment.
Discussion
The Pennsylvania Rules of Civil Procedure govern the discovery of medical
expert testimony. The rules state:
(1) A party may through interrogatories require
(a) any other party to identify each person whom
the other party expects to call as an expert witness at
trial and to state the subject matter on which the expert
is expected to testify and
(b) the other party to have each expert so identified
by him state the substance of the facts and opinions to
which the expert is expected to testify and a summary of
the grounds for each opinion. The party answering the
interrogatories may file as 'his answer a report of the
expert or have the interrogatories answered by his
expert. The answer or separate report shall be signed by
the expert.
97-857 CIVIL TERM
Pa. R. Civ. P. 4003.5(a).
In this nursing malpractice case, Stone claims he was injured while in the
care of nurses at the Carlisle Hospital. Defendant filed interrogatories for the
purpose of learning the name of an expert to be called, together with the expert
report. Plaintiffs responded by supplying the names of three of Stone's treating
physicians but forwarded no reports. Defendant believes that Plaintiffs will not
have an expert testify at trial.
In Pennsylvania, the general rule in medical malpractice actions is that "a
plaintiff must present expert testimony to establish to a reasonable degree of
medical certainty that the defendant's acts deviated from an accepted medical
standard, and that such deviation was the proximate cause of the harm suffered."
Welsh v. Bulger, 548 Pa. 504, 513, 698 A.2d 581,585 (1997). An exception to the
rule exists where the defendant's act of negligence are so obvious that lay persons
can comprehend the negligence without the aid of expert testimony. Id. Cases
which have held that expert testimony is necessary to present a prima facie case
for medical malpractice include: Brophy v. Brizuela, 358 Pa. Super. 400, 517 A.2d
1293 (1986)(rendering of plaintiff's expert opinion to be inadmissible, for failure to
respond to interrogatories, made it impossible to present a prima facie case for
medical malpractice where plaintiff became pregnant after undergoing a tubal
3
97-857 CIVIL TERM
ligation); Mitzelfelt v, Kamrin, 379 Pa. Super. 121,549 A.2d 935 (1988), rev'd on
other grounds, 526 Pa. 54, 584 A.2d 888 (1990)(requiring expert testimony to
prove that neurological surgery gone awry was the cause of quadriplegia); Cohen
v. Albert Einstein Med. Center., 405 Pa. Super. 392, 592 A.2d 720 (1991)(requiring
expert testimony where plaintiff suffered nerve damage after receiving an
intramuscular injection). The above cases can be contrasted with cases that have
held that expert opinion is not necessary. These cases include: Brannan v.
Lankenau Hospital, 490 Pa. 588, 417 A.2d 196 (1980)(finding exception to a rule
requiring expert testimony applies where negligence was so obvious that a lay
person could comprehend it, because intensive care nursing staff failed to notify
treating physician of plaintiff's deteriorating, post operative condition); Gregorio v.
Zeluck, 451 Pa. Super. 154, 678 A.2d 810 (1996)(stating that leaving a sponge in
a patient after a surgical procedure is such obvious negligence that expert
testimony is not required); Brown v. Philadelphia College of Osteopathic Medicine,
449 Pa. Super. 667, 674 A.2d 1130 (1996)(holding that expert testimony is not
necessary to present a prima facie case of negligent infliction of emotional distress
where plaintiff was left alone in an exam room where she miscarried, the fetus was
left on the exam bed for fifteen minutes with the plaintiff, and when the fetus was
97-857 CIVIL TERM
removed it was placed, in plaintiff's arms for photos to be taken).1
In the case at bar, Defendant requests summary judgment because it
believes that the Plaintiff can not present a prima facie case for nursing malpractice
without expert opinion concerning the nursing standard of care. The Pennsylvania
Rules of Civil Procedure state:
If the identity of an expert witness is not disclosed in
compliance with subdivision (a)(1) of this rule, he shall
not be permitted to testify on behalf of the defaulting
party at the trial of the action. However, if the failure to
disclose the identity of the witness is the result of
extenuating circumstances beyond the control of the
defaulting party, the court may grant a continuance or
other appropriate relief.
Pa. R. Civ. P. 4003.5(b). According to Pa. R. Civ. P. 4003.5(b), a court may
prevent a party from presenting expert testimony at trial if the party has not
complied with the discovery rules found in Pa. R. Civ. P. 4003.5(a). The question
of whether expert testimony is required in order to present a prima facie case for
medical malpractice cannot be addressed by a court until it has decided if the party
is permitted to present expert testimony at trial.
Defendant's motion for summary judgment, addressed in this opinion, is
'The above cases are along the lines of res ipsa Ioquitur where negligence
is so egregious that no expert is needed. These cases all show, beyond a doubt,
that the negligence is so clear that at completion of the plaintiff's case in chief at
trial, the evidence can clearly withstand a motion for directed verdict.
5
97-857 CIVIL TERM
premature. Defendant has not filed a motion to compel the disclosure of an expert
who is willing to testify at trial and the expert report. If Defendant files such a
motion, the Court may order the Plaintiffs to disclose the identity of an expert within
a set number of days. If Plaintiff fails to respond or continues to refuse to name
an expert willing to testify at trial, Defendant can file a motion for sanctions to
preclude Plaintiffs' presentation of an expert witness at trial. If sanctions are
awarded, Defendant could file a second motion for summary judgment, contending
that Plaintiffs cannot present a prima facie case for nursing malpractice because
Plaintiffs have been .precluded from presenting expert testimony. Until these
procedural steps are taken, the question of whether Plaintiffs must present expert
testimony to avoid summary judgment cannot be addressed by this Court.2
Because Plaintiffs have not yet been precluded from presenting an expert witness
at trial, Defendant's motion for summary judgment is premature and therefore
denied.
2Plaintiff may choose to present their negligence case without the use of
expert testimony. From our view of the record, it does not appear that the Plaintiffs
will be able to take advantage of any charge from the court resembling a res ipsa
Ioquitur type of charge and that any requests for a directed verdict may be granted
at the close of Plaintiffs' case in chief. However, because the facts are in dispute,
we cannot say that a motion for summary judgment is appropriate at this point,
regardless of how Plaintiffs choose to present their evidence.
6