Bernardo & Rosa Figueroa, Res. v. Thomas Ryan, M.d., App.

CourtCourt of Appeals of Washington
DecidedOctober 14, 2013
Docket68272-5
StatusUnpublished

This text of Bernardo & Rosa Figueroa, Res. v. Thomas Ryan, M.d., App. (Bernardo & Rosa Figueroa, Res. v. Thomas Ryan, M.d., App.) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bernardo & Rosa Figueroa, Res. v. Thomas Ryan, M.d., App., (Wash. Ct. App. 2013).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

BERNARDO FIGUEROA and ROSA FIGUEROA, husband and wife, No. 68272-5-

Respondents, DIVISION ONE

v. UNPUBLISHED OPINION £^ © 2 —-^ HIGHLINE MEDICAL CENTER, a —, """•—4

Washington non-profit corporation,

Defendant, 3iL — ». THOMAS RYAN, M.D., " —IO

Appellant,

and HIGHLINE EMERGENCY PHYSICIANS, PLLC, a Washington Professional Limited Liability Company, FILED: October 14, 2013

Defendant.

Grosse, J. — Generally, all relevant evidence is admissible except as

limited by constitution, statute, or other evidentiary rule.1 In a medical malpractice suit, physicians may testify as to their professional conduct that is

repeatedly and consistently performed when treating persons with similar

symptoms so long as it is relevant. Here, the trial court did not abuse its

discretion in excluding certain evidence offered by defendant-physician because

the conduct described did not meet the standard for habit evidence.

Nor did the trial court abuse its discretion in its other evidentiary rulings or

in declining to give an instruction proffered by the defendant-physician,

particularly here, where the jury received proper standard of care instructions and

1SeeER401. No. 68272-5-1 / 2

was accurately instructed on the law and permitted the defendant-physician to

argue his theory of the case. The trial court is affirmed.

FACTS

At approximately 3:00 p.m., on October 3, 2005, Bernardo Figueroa's wife,

Rosa, drove him to Highland Hospital's emergency room because he was

experiencing abdominal pain. Dr. Thomas Ryan examined Figueroa and ordered

a computed tomography (CT) scan to rule out appendicitis. An intravenous (IV)

needle was attached to Figueroa's right hand. When contrast dye was injected,

Figueroa experienced a great deal of pain. Approximately 60 milliliters of the IV

fluid with the contrast dye escaped from the vein. The medical term for this event

is extravasation. Usually extravasation results in swelling and pain, which is

treated by ice, elevation, and observation. In rare instances, extravasation can

result in compartment syndrome, which, if left untreated, can result in the

collapse of the veins.2 The treatment for compartment syndrome is a fasciotomy, a surgery in which the fascia (connective tissue) surrounding the veins is cut until

the pressure decreases and the affected vessels can re-expand. If not treated in

a timely manner, compartment syndrome can cause partial paralysis.

After the IV was removed, Figueroa returned to the emergency room with

extravasation, still experiencing pain and swelling in his arm. His arm was

elevated and ice was applied to reduce swelling. Dr. Ryan ordered a Demerol

injection for pain, after which Figueroa experienced less pain. The CT scan

result was negative for appendicitis and Figueroa was discharged at 5:28 p.m.

Compartment is a part of the body that is enclosed by thick connective tissue. No. 68272-5-1 / 3

Figueroa continued to experience pain at home and when it became

unbearable, he returned to the emergency room at 9:40 p.m. Figueroa

presented with forearm pain, numbness, and swelling. Figueroa was diagnosed

with compartment syndrome and was immediately transferred to the Burien

Hospital campus for surgery, where Dr. Vincent Muoneke performed an

emergency fasciotomy approximately eight hours after the extravasation.

In the following days, Figueroa continued to experience problems with his

arm and was referred to Dr. Clark for a second opinion. Dr. Clark observed that,

because the operation took place over six hours after the extravasation, the

operation did not totally repair the damage from the compartment syndrome.

Because of this injury, Figueroa continues to experience "decreased motion,

significant stiffness and continued pain as well as parathesia in the median nerve

distribution

At trial, the defense sought to impeach Figueroa's description of his

inability to perform certain actions by showing a video recording of Figueroa

performing some operations with his arm that he claimed he was unable to do.

Figueroa offered rebuttal testimony explaining some of those actions. The matter

went to the jury who found for Figueroa and awarded him $122,000.00.

Dr. Ryan appeals, raising a variety of evidentiary rulings and instructional

error.

ANALYSIS

Dr. Ryan contends the trial court's rulings on a variety of evidentiary

issues resulted in a one-sided presentation of evidence and prevented him from No. 68272-5-1 / 4

defending the suit. A trial court's decisions to admit or exclude evidence are

reviewed for abuse of discretion.3 "A trial court abuses its discretion when its

decision 'is manifestly unreasonable or based on untenable grounds or

reasons.'"4

Evidence of Habit

Dr. Ryan argues that the trial court improperly precluded him from

testifying as to his habit and routine practice of orally instructing patients with

compartment syndrome. Evidence of the habit of a person, whether

corroborated or not and regardless of the presence of eyewitnesses, is relevant

to prove that the conduct of the person on a particular occasion conformed to

habit or routine.5 Under ER 406, relevant evidence is admissible to prove

behavior in conformity with habit on a particular occasion.6 Washington courts have found a broad range of conduct to rise to the level of habit. Courts consider

the regularity of the behavior and the surrounding circumstances in determining

whether particular conduct rises to the level of habit, as it is "'the notion of the

invariable regularity that gives habit evidence its probative force.'"7 In Meyers v.

3 Salas v. Hi-Tech Erectors. 168 Wn.2d 664, 668, 230 P.3d 583 (2010). 4 Salas, 168 Wn.2d at 668-69 (quoting State v. Stenson, 132 Wn.2d 668, 701, 940P.2d 1239(1997)). 5 ER 406. 6 ER 406 provides: Evidence of the habit of a person or of the routine practice of an organization, whether corroborated or not and regardless of the presence of eyewitnesses, is relevant to prove that the conduct of the person or organization on a particular occasion was in conformity with the habit or routine practice. See also Mevers v. Meyers. 81 Wn.2d 533, 503 P.2d 59 (1972). 7 State v. Thompson, 73 Wn. App. 654, 659 n.4, 870 P.2d 1022 (1994) (quoting comment to ER 406); see also State v. Young, 48 Wn. App. 406, 739 P.2d 1170 No. 68272-5-1 / 5

Meyers, the Supreme Court found testimony offered by a defendant about her

standard business practices admissible, even though such behavior required

some degree of conscious action as opposed to being a nearly involuntary or

automatic response to given stimuli.8 Meyers involved a notary public who was permitted to testify it was her professional habit to always ask for identification

before notarizing a document. Moreover, the Meyers court held that the

exclusion ofsuch testimony would be reversible error.9 However, not all behavior claimed as regular and consistent in similar

circumstances is admissible as habit evidence under ER 406. For example, in

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