Betty Freeman v. Conway Regional Medical Center

2020 Ark. App. 488, 612 S.W.3d 193
CourtCourt of Appeals of Arkansas
DecidedOctober 28, 2020
StatusPublished

This text of 2020 Ark. App. 488 (Betty Freeman v. Conway Regional Medical Center) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Betty Freeman v. Conway Regional Medical Center, 2020 Ark. App. 488, 612 S.W.3d 193 (Ark. Ct. App. 2020).

Opinion

Cite as 2020 Ark. App. 488 Reason: I attest to the accuracy and integrity of this ARKANSAS COURT OF APPEALS document DIVISION IV Date: 2021-07-15 14:05:09 Foxit PhantomPDF Version: No. CV-19-958 9.7.5

Opinion Delivered: October 28, 2020 BETTY FREEMAN APPELLANT APPEAL FROM THE FAULKNER V. COUNTY CIRCUIT COURT [NO. 23CV-18-615] CONWAY REGIONAL MEDICAL CENTER, JOHN/JANE DOE RN 1–4, JOHN/JANE DOE LPN AND CNA 1– HONORABLE SUSAN WEAVER, 4, AND JOHN DOE DIRECT ACTION JUDGE INSURANCE CARRIER APPELLEES AFFIRMED

RITA W. GRUBER, Chief Judge

This is a medical-malpractice case arising out of the care and treatment provided to

appellant Betty Freeman. Freeman appeals from two orders dismissing her complaint against

appellees Conway Regional Medical Center; Laura Grider, RN; and Lathecia Greenlee,

LPN. For reversal, Freeman argues that the circuit court erred in granting summary

judgment to Grider and Greenlee on the basis that her claim was barred by the statute of

limitations. We affirm.

On April 25, 2016, Betty Freeman fell in the shower while hospitalized at Conway

Regional Medical Center (CRMC), causing injuries to her back, neck, head, and legs.

Freeman filed a negligence action on April 24, 2018, naming CRMC as a defendant along

with “John/Jane Doe RN 1–5. John/Jane Doe LPN and CNA 1– and John Doe Direct

Action Insurance Carrier.” In regard to the John/Jane Doe RN, LPN, and CNA defendants, Freeman alleged that their actual identity was unknown to her but would be determined

during the discovery process. Freeman’s counsel filed an affidavit with the complaint

pursuant to Arkansas Code Annotated section 16-56-125 (Repl. 2005) stating that the

identity of the John Doe tortfeasors was unknown. The facts alleged included the following:

(1) Freeman was transported by ambulance on April 24, 2016, to CRMC after experiencing

dizziness at her home; (2) the emergency medical technicians reported Freeman was

suffering from weakness, slurred speech, and facial droop and was suspected of having had

a stroke; (3) she was admitted to the hospital, and a sign was placed outside her door that

she was to be assisted in standing and with bathroom needs; (4) on April 25 she made a

request to nursing staff to take a shower; (5) an “unknown member of the staff presumed

by [Freeman] and her husband to be a nurse” assisted her out of bed and into the shower

and then left her unattended and exited her hospital room not to return; and (6) Freeman

suddenly fell in the shower, causing injuries. The complaint further alleged that the “RN’s,

LPN’s, and CNA’s” failed to use ordinary care to prevent the fall of a patient who was

known to be incapable of standing or walking without assistance, that they owed her a duty

to follow the medical directives and protocols related to a patient at risk for falling or unable

to walk, and that their failure to exercise ordinary care when she was taken to the shower

constituted negligence and was the sole and proximate cause of her injuries. Freeman also

alleged that the “RN’s, LPN’s, and CNA’s” were employees of CRMC such that their acts

or omissions are imputed to CRMC under the doctrine of respondeat superior.

Freeman filed an amended complaint on August 17, 2018, substituting “Laura

Grider, RN” for “Jane Doe 1, RN” and “Lathecia Greenlee, CNA” for “Jane Doe 1,

2 CNA.” Freeman alleged that Grider and Greenlee were members of her patient-treatment

team at the time of the incident. Grider and Greenlee filed an answer on August 27, 2018,

followed by a motion to dismiss on the ground that Freeman’s complaint was barred by the

statute of limitations. Specifically, Grider and Greenlee argued that because the alleged facts

occurred on April 25, 2016, and Freeman named them for the first time in the August 17,

2018, complaint, her complaint was beyond the two-year statute of limitations set out in

Arkansas Code Annotated section 16-114-203 (Repl. 2016) for medical-malpractice actions

and should be dismissed.

In response, Freeman contended that prior to filing her complaint, she was unable to

identify the names of the nurses and CNAs who treated her on April 25 based on a review

of her medical records. She argued the identity of Grider and Greenlee was unknown to

her “because their names were not located in, nor could their names be identified” in her

medical records. She stated that she did not learn of their identity until CRMC provided

discovery responses on August 14, 2018, which prompted the August 17 amended

complaint substituting Grider and Greenlee for two of the Jane/John Doe defendants.

Freeman attached CRMC’s discovery responses as exhibit A; interrogatory No. 12 provided

that Laura Grider was the RN on duty, and Lathecia Greenlee was the aide on duty when

Freeman was taken to the shower. As such, Freeman argued that the complaint complied

with the John Doe statute as well as the requirements of Rule 15(c) of the Arkansas Rules

of Civil Procedure addressing the relation back of amendments.

Greenlee and Grider replied that Freeman knew or should have known at the time

she filed her original complaint that they provided care to her on April 25, and thus the

3 John Doe statute and Rule 15(c) are inapplicable. Specifically, they argued that the medical

records “clearly and specifically show” they cared for Freeman on that date, and they

attached Freeman’s medical records as an exhibit. They elaborated that the author of a note

is identified by initials in the electronic medical record and stated that if there was ever a

question as to the identity of a person whose initials appear in the record, the record also

contains a “signature sheet or ‘User Key’ clearly informing the reader” who is identified by

the initials. They stated that based on this fact, Freeman’s argument that the “medical records

did not contain the names” of Grider and Greenlee is without merit. Grider and Greenlee

relied on Stephens v. Petrino, 350 Ark. 268, 86 S.W.3d 836 (2002).

Upon Freeman’s request, a hearing on the motion to dismiss was held on July 31,

2019; however, Freeman’s counsel failed to attend. The circuit court orally granted the

motion and entered an order on August 5, 2019, dismissing the complaint against Grider

and Greenlee with prejudice.1 In granting the motion, the order indicated that the court

had considered the separate defendants’ motion, Freeman’s response, and separate

defendants’ reply, along with the exhibits attached. Freeman filed a timely notice of appeal

from that order on September 4, 2019.

On August 16, 2019, CRMC filed a motion for summary judgment on the basis that

the dismissal with prejudice of Grider and Greenlee extinguished its liability in the case

because Freeman’s complaint against them was based on vicarious liability. On November

1 After the order was entered, Freeman’s counsel filed a motion for findings of fact and conclusions of law, which was denied. See Ark. R. Civ. P. 52(a) (providing in part that findings of fact and conclusions of law are unnecessary on decisions of motions under the rules).

4 6, the circuit court entered on order granting CRMC’s motion for summary judgment and

dismissing Freeman’s complaint against CRMC with prejudice. Freeman filed a timely

notice of appeal on November 20.

Although Grider and Greenlee’s motion leading to the order at issue was styled as a

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Bluebook (online)
2020 Ark. App. 488, 612 S.W.3d 193, Counsel Stack Legal Research, https://law.counselstack.com/opinion/betty-freeman-v-conway-regional-medical-center-arkctapp-2020.