Atlanta Emergency Services, LLC v. Linda Clark

CourtCourt of Appeals of Georgia
DecidedJuly 8, 2014
DocketA14A0469
StatusPublished

This text of Atlanta Emergency Services, LLC v. Linda Clark (Atlanta Emergency Services, LLC v. Linda Clark) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Atlanta Emergency Services, LLC v. Linda Clark, (Ga. Ct. App. 2014).

Opinion

FOURTH DIVISION DOYLE, P. J., MILLER and DILLARD, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. http://www.gaappeals.us/rules/

July 8, 2014

In the Court of Appeals of Georgia A14A0469. ATLANTA EMERGENCY SERVICES, LLC v. CLARK.

DILLARD, Judge.

Linda Clark, M.D., sued Atlanta Emergency Services, LLC (“AES”), alleging

that AES breached a contract between the parties when it terminated her employment

as an emergency-room physician at Piedmont Hospital. Following a jury verdict and

judgment in Dr. Clark’s favor, AES appeals, arguing that the trial court erred in

denying its motions for directed verdict and judgment notwithstanding the verdict

(j.n.o.v.). Specifically, AES contends that no genuine issues of material fact support

Dr. Clark’s claims for breach of contract or attorney fees and that the jury’s damages

award was unlawful. For the reasons set forth infra, we affirm the jury’s verdict and

the trial court’s judgment. Construed in favor of the jury’s verdict,1 the evidence shows that AES is an

operating entity of a private company known as the Schumacher Group, which is

engaged in the business of providing emergency-medicine-practice management to

both small and large hospitals throughout the southeast. Toward that end, the

Schumacher Group, via its operating entities such as AES, contracts with hospitals

to provide physician staffing for the hospitals’ emergency departments and does so

by recruiting independent-contractor physicians. From July 2010 until April 2012,

AES provided Piedmont Hospital with emergency-department physicians pursuant

to such a contract.

In July 2010, Dr. Clark, a board-certified emergency-room physician, entered

into an employment contract with AES, titled “Physician Agreement,” to work in the

emergency department at Piedmont Hospital. The agreement included a provision,

designated as Section 7, that outlined the means by which the agreement—and the

physician’s employment—could be terminated. Subsection (a), in part, provided: “this

Agreement shall be subject to termination without cause by either party giving not

less than sixty (60) days prior written notice to the other party specifying the date of

termination.” In contrast, subsection (b), in part, provided: “Corporation may also

1 See, e.g., Horton v. Hendrix, 291 Ga. App. 416, 416 (662 SE2d 227) (2008).

2 terminate this Agreement immediately in the event that . . . (v) Hospital requests the

removal of Physician or reports that Physician is being disruptive, unprofessional, or

unreasonably uncooperative with the medical or administrative staff of Hospital. . .

.”

Over the course of the next year, the medical director of AES, Dr. Michael

Flueckiger, who was also an emergency-department physician at Piedmont Hospital,

received over a dozen complaints from nurses in the emergency department, stating

that Dr. Clark treated them rudely and/or disrespectfully. During that same period of

time, despite the fact that it was undisputed that she was a competent emergency-

department physician, Dr. Flueckiger also received similar complaints about Dr.

Clark from other physicians on staff at Piedmont, as well as from several emergency-

room patients. Consequently, in late July 2011, Dr. Flueckiger and Cynthia Troutman,

AES’s nurse liaison to Piedmont Hospital, met with Dr. Clark to discuss means by

which to resolve these issues and prevent their recurrence.

Nevertheless, on September 25, 2011, Troutman and Dr. John Limehouse,

AES’s assistant medical director at Piedmont Hospital, met with Dr. Clark and

informed her that her employment was being terminated without cause effective in

60 days and, thus, her last day of employment would be November 24, 2011. During

3 this meeting, Dr. Clark requested written notice regarding this termination decision,

but none was ever provided to her. Then, on October 26, 2011, the new medical

director for AES requested that Dr. Clark participate in a conference call, at which

time he informed her that her employment was being terminated immediately for

cause based on a request by the administration of Piedmont Hospital. Later, however,

Dr. Clark learned that the decision to terminate her employment for cause was made

by AES and that Piedmont Hospital had made no such request.

On January 18, 2012, Dr. Clark filed a lawsuit against AES, alleging that AES

breached the Physician Agreement when it terminated her employment for cause

despite the fact that the conditions required for such a termination were not satisfied.

Dr. Clark’s complaint also alleged that AES’s actions constituted bad faith, and thus,

she sought to recover attorney fees as well as lost income. AES filed an answer, and

after discovery closed, it moved for summary judgment, arguing that its termination

of Dr. Clark’s employment for cause was authorized by the unambiguous terms of the

Physician Agreement. In response, Dr. Clark argued that summary judgment was

precluded because the agreement was ambiguous regarding whether complaints from

individual nurses and physicians constituted “reports” from the “Hospital” that Dr.

Clark was “disruptive, unprofessional, or unreasonably uncooperative with the

4 medical or administrative staff of Hospital.” Following a hearing, the trial court

denied AES’s motion and, later, denied AES’s motion for reconsideration of the

issue.

The case then proceeded to trial. And after Dr. Clark rested, AES moved for

a directed verdict as to all of her claims, but the trial court reserved ruling. AES then

presented its evidence, and at the conclusion of the trial, the jury found in favor of Dr.

Clark and, pursuant to a general-verdict form, awarded her $61,721.02 in damages.

Thereafter, the trial court made the jury’s verdict its final judgment. Subsequently,

AES filed a motion for j.n.o.v., which the trial court denied after a hearing. This

appeal follows.

1. AES contends that the trial court erred in denying its motions for directed

verdict and j.n.o.v.,2 arguing that the termination provision in the Physician

Agreement is unambiguous and, thus, no genuine issues of material fact support Dr.

Clark’s claim for breach of contract. We disagree.

2 AES also contends that the trial court erred in denying its motion for summary judgment and motion for reconsideration regarding these issues, but “after a verdict and judgment, review of an order denying summary judgment is moot.” Rowe v. Law Offices of Ben C. Brodhead, P.C., 319 Ga. App. 10, 16 (3) n.7 (735 SE2d 39) (2012).

5 It is, of course, axiomatic that on appeal from the denial of a motion for a

directed verdict or a motion for j.n.o.v., we construe the evidence “in the light most

favorable to the party opposing the motion, and the standard of review is whether

there is any evidence to support the jury’s verdict.” 3 In fact, because the jurors are the

“sole and exclusive judges of the weight and credit given the evidence,” we must

construe the evidence with “every inference and presumption in favor of upholding

the verdict, and after judgment, the evidence must be construed to uphold the verdict

even where the evidence is in conflict.”4 However, we review questions of law de

novo.5 With these guiding principles in mind, we turn now to AES’s specific claims

of error.

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