Aumand et al. v. DHMC

2009 DNH 061
CourtDistrict Court, D. New Hampshire
DecidedMay 1, 2009
DocketCV-06-434-JL
StatusPublished

This text of 2009 DNH 061 (Aumand et al. v. DHMC) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aumand et al. v. DHMC, 2009 DNH 061 (D.N.H. 2009).

Opinion

Aumand et a l . v . DHMC CV-06-434-JL 05/01/09 P UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

Deborah C . Aumand and Francis Coffey

v. Civil N o . 06-cv-434-JL Opinion N o . 2009 DNH 061 Dartmouth Hitchcock Medical Center

O R D E R

The plaintiffs, who are the executor of the estate of

Katherine Coffey and Coffey’s widower, Francis Coffey, have sued

Dartmouth Hitchcock Medical Center, alleging that it provided

negligent medical care to Coffey during her hospitalization

there, leading to an infection, the amputation of parts of her

hand, and ultimately her death.1 This court has jurisdiction

under 28 U.S.C. § 1332(a)(1) (diversity). Each side has filed a

number of motions in limine seeking to exclude certain evidence

from the upcoming trial. After oral argument, and for the

foregoing reasons, the court makes the following rulings on the

motions in limine.

1 The court will refer to Katherine Coffey as “Coffey,” and Francis Coffey as “Francis Coffey.” I. Background

The following facts are drawn from the allegations of the

plaintiffs’ third amended complaint and their representations in

the motions themselves. Coffey, who was seventy-eight years old

at the time, was discharged from Dartmouth Hitchcock following

successful coronary bypass surgery, but was readmitted two days

later complaining of shortness of breath. Detecting low blood

sugar, hospital personnel proceeded to administer several doses

of glucose, or “D-50,” to Coffey over a period of roughly six

hours, by way of a catheter inserted into her left hand. After

the last of these administrations, however, hospital personnel

noted that her left hand appeared blue and swollen, so the

catheter was removed and replaced with one in her left elbow.

Coffey soon began complaining of numbness in her hand,

leading hospital personnel to believe that the glucose had

“infiltrated” or “extravasated,” i.e., penetrated the tissue

outside of her veins. Though Coffey was discharged from

Dartmouth Hitchcock approximately two weeks later, transferring

to Springfield Rehabilitation Center in Springfield, Vermont,

the condition of her left hand continued to deteriorate. She was

readmitted to Dartmouth Hitchcock roughly one week later, when

two of her fingers and part of another on her left hand--which

had undergone mummification--were amputated.

2 After the surgery, Coffey reentered Springfield

Rehabilitation for about two weeks, during which both pus and

blood were observed draining from her wounds. She also saw her

surgeon, who concluded that Coffey would need a skin graft to her

left hand. That procedure, performed during a one-day visit to

Dartmouth Hitchcock, used skin harvested from Coffey’s abdomen.

In two weeks, Coffey returned to Springfield Rehabilitation,

complaining of shortness of breath and dry heaves, followed by a

high fever, low blood pressure, and respiratory distress which

appeared after her admission. Testing indicated a serious

infection, specifically methicillin-resistant staphylcoccus

areus, or MRSA, which the plaintiffs characterize as a bacterial

strain often contracted during hospital stays. The next day,

Coffey died from a heart attack brought on by the infection.

Both the doctor who performed an autopsy, and another whom

the plaintiffs retained as an expert witness for this litigation,

identified the wounds from the amputation as the probable portal

of entry for the MSRA. The plaintiffs claim that the amputation,

in turn, came about only as a result of Dartmouth Hitchcock’s

alleged negligence during its treatment of Coffey’s low blood

sugar during her first readmission to that hospital.

Specifically, the plaintiffs claim that Dartmouth Hitchcock

violated the standard of care by (1) failing to provide Coffey

3 with “appropriate nutrition,” (2) “failing to fully inform the

attending physician,” (3) improperly administering glucose,

particularly by (4) “pushing” it through the catheter into her

hand, and (5) not recognizing promptly that the glucose had

infiltrated and caused extravasation. The third amended

complaint asserts a medical malpractice claim on behalf of

Coffey’s estate, as well as loss of consortium claim on behalf of

Francis Coffey; a third claim, for negligent infliction of

emotional distress on behalf of Francis Coffey, has been

voluntarily dismissed. Dartmouth Hitchcock denies any deviation

from the standard of care, or any link between its actions and

Coffey’s injuries, up to and including her death.

II. Analysis

A. Plaintiffs’ motion “regarding infiltration/extravasation”

The plaintiffs seek to prevent Dartmouth Hitchcock from

asserting at trial that Coffey did not, in fact, experience

infiltration of the glucose, arguing that the hospital has not

disclosed any expert testimony to that effect. In response,

Dartmouth Hitchcock explains that, while it does not intend to

proffer such expert testimony, it nevertheless remains free to

present other kinds of evidence tending to suggest than no

4 infiltration occurred, as well as to question whether the

plaintiffs have carried their burden to prove otherwise.

Dartmouth Hitchcock has the better of this argument. While

New Hampshire law requires expert testimony to prove the

essential elements of a medical malpractice case, i.e., the

standard of care, a breach of that standard, and causation, N.H.

Rev. Stat. Ann. (“RSA”) § 507-E:2, it does not follow that a

party to such a case cannot take a position on what did or did

not occur as a factual matter without expert testimony

affirmatively supporting that position.2 The only limit on the

positions a party can take--as distinguished from the evidence a

party can introduce--would seem to be the general rule against

“arguments prejudicial to the opposing party which are not

supported by facts in evidence, or which are beyond the limits of

fair or sound argument, unduly influencing or distracting the

2 The plaintiffs cite the New Hampshire Supreme Court’s recent decision in Goudreault v . Kleeman, 965 A.2d 1040 (N.H. 2009), but it is not to the contrary. In relevant part, Goudreault holds only that, in order for the jury in a medical malpractice case to consider “apportioning professional liability” to non-parties, a defendant must affirmatively show the negligence of those non-parties by expert testimony in accordance with RSA 507-E:2. Id. at 1057. It does not hold that a medical malpractice defendant must adduce expert testimony to support any position it takes at trial.

5 jury.”3 75 Am. Jur. 2d Trial § 4 1 4 , at 632 (2007) (footnote

omitted).

Dartmouth Hitchcock’s anticipated arguments do not fit that

description. Based on the evidence cited in its objection to

this motion, Dartmouth Hitchcock has a factual basis to argue

that no infiltration occurred. And, even without that evidence,

Dartmouth Hitchcock remains free to argue that the plaintiffs

have not carried their burden to show that infiltration did

occur. Indeed, at oral argument, the plaintiffs more or less

withdrew this motion, characterizing it as simply an attempt to

prevent Dartmouth Hitchcock from offering undisclosed expert

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