Blake Huegel, V. D.s.h.s., State Of Wa

CourtCourt of Appeals of Washington
DecidedNovember 21, 2024
Docket59660-1
StatusUnpublished

This text of Blake Huegel, V. D.s.h.s., State Of Wa (Blake Huegel, V. D.s.h.s., State Of Wa) 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
Blake Huegel, V. D.s.h.s., State Of Wa, (Wash. Ct. App. 2024).

Opinion

Filed Washington State Court of Appeals Division Two

November 21, 2024

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II BLAKE HUEGEL, No. 59660-1-II

Appellant,

v.

STATE OF WASHINGTON DEPARTMENT UNPUBLISHED OPINION OF SOCIAL AND HEALTH SERVICES,

Respondent.

GLASGOW, J.—WS, a vulnerable adult, lived in an adult family home, Vintage Years. WS’s

bed at Vintage Years was placed against a wall on one side and he had an upper bed rail installed

on his bed on the other side. At WS’s family’s request, Blake Huegel, a temporary caregiver at

Vintage Years, then installed a lower bed rail on WS’s bed.

An upper bed rail starts at the head of the bed, runs along the side of the bed, and is about

three feet long. A lower bed rail is the same length and starts at the foot of the bed. When both an

upper and a lower bed rail are installed, there is an approximately one-and-a-half-foot gap between

them. The lower bed rail that Huegel installed was not medically approved and left WS only a

narrow gap between bed rails to exit his bed. Within a day of Huegel installing the lower bed rail,

WS fell while getting out of bed and died several days later from a subdural hematoma.

The Department of Social and Health Services (the Department) investigated Huegel and

found that he abused a vulnerable adult by improperly using a mechanical restraint, the lower bed

rail. During the investigation, Huegel admitted that he installed the lower bed rail on WS’s bed No. 59660-1-II

without medical authorization and that he knew this violated regulations. After a hearing, an

administrative law judge affirmed the abuse finding against Huegel. The Department’s Board of

Appeals (the Board) affirmed the administrative law judge’s finding. The superior court affirmed

the Board’s order. Huegel appeals.

We conclude that the Board’s unchallenged findings are verities on appeal. The Board

appropriately considered hearsay evidence in this administrative proceeding, where hearsay is

permitted if it is the type of evidence on which a reasonably prudent person would rely. And the

three findings that Huegel challenges are supported by substantial evidence in the record, including

Huegel’s admissions during the investigation. The Board correctly applied the plain language of

the abuse of a vulnerable adult standard because it includes the improper restraint of a vulnerable

adult without medical authorization. The Board did not have to find that Huegel intended to injure

WS. Finally, we recognize that the abuse finding has significant consequences, especially where

WS’s injuries were the result of an unfortunate accident. But under current law, placement on the

registry of those who have abused vulnerable adults did not violate Huegel’s procedural due

process rights.

We affirm. We deny Huegel’s request for appellate attorney fees.

FACTS

I. BACKGROUND FACTS

The following facts are drawn primarily from the unchallenged findings of fact in the

Board’s final order, which are verities on appeal. Postema v. Pollution Control Hr’gs Bd., 142

Wn.2d 68, 100, 11 P.3d 726 (2000).

2 No. 59660-1-II

Blake Huegel was a licensed certified nursing assistant working in adult long-term care.

He had nine years of experience in long-term care and ran multiple adult family homes. Huegel

occasionally assisted his brother, Cameron Huegel, at Vintage Years, an adult family home that

Cameron operated in Battle Ground, Washington. At Vintage Years, Huegel acted as a “fill-in

caregiver” when Cameron was unavailable. Verbatim Rep. of Proc. (VRP) at 213. Huegel

completed a training in 2016 that explicitly included “[w]hat constitutes a restraint.” Admin. Rec.

(AR) at 3. Under Washington law, a restraint includes “any device attached or adjacent to the

vulnerable adult’s body that [they] cannot easily remove that restricts freedom of movement or

normal access to [their] body.” Former RCW 74.34.020(15) (2019).

A. WS’s Admission to Vintage Years and Initial Assessments

WS, a 90-year-old man, began living at Vintage Years in November 2019 after falling at

home and suffering severe injuries. Before WS entered the home, Vintage Years filled out a long-

term care assessment for him. The care assessment noted that WS was “disoriented” and

“attempted to get out of bed.” AR at 6, 264. It recommended that caregivers should keep WS’s

bed low to the floor, remind WS to use a call signal when getting out of bed, and use a bed alarm.

Vintage Years also completed a care plan for WS. The care plan did not mention bed rails, but it

stated that WS was at risk for falls and that Vintage Years would keep his bed low to the ground.

In December 2019, WS attempted to get out of bed by himself and fell. He was taken to

the hospital and treated for an injured hip before returning to Vintage Years in January 2020.

B. After WS’s December 2019 Fall

In December, after WS’s fall, a nurse at Vintage Years completed a bed rail assessment for

WS. A “bed rail,” also called a “side rail,” is an assistive device that can be placed on beds to help

3 No. 59660-1-II

residents reposition and maneuver in and out of bed. An upper bed rail starts at the head of the

bed, runs along the side of the bed, and is about three feet long. A lower bed rail is the same length

and starts at the foot of the bed. When both an upper and a lower bed rail are installed, there is an

approximately one-and-a-half-foot gap between them. Many adult care facility residents use upper

bed rails for mobility purposes; residents can use the upper rail to brace or steady themselves when

turning over in bed, sitting up, or getting out of bed. When he lived at home, WS had upper bed

rails on his bed.

The nurse, Cameron Huegel, and Polly Little, WS’s daughter, all signed WS’s bed rail

assessment. The bed rail assessment noted that Little requested rails for WS for his “safety and

mobility.” AR at 10. The bed rail assessment included a section on the risks of bed rails, stating

that “serious injuries can occur from falls if an individual climbs over the bed rails,” and that bed

rails “can induce agitation if the rail is perceived as a restraint.” AR at 11. Little consented to these

risks and indicated that she wanted to have upper bed rails placed on both sides of WS’s bed.

Ultimately, the bed rail assessment concluded that no bed rails should be used “[d]ue to

positioning.” AR at 12. This assessment contained no further explanation. This was the only bed

rail assessment that Vintage Years conducted for WS.

During WS’s follow-up visit from the December fall, his primary care provider, Dr.

Gregory Hallas, noted that WS’s behavior had changed significantly, including increased agitation.

In Dr. Hallas’ report, which he faxed to Vintage Years, he ordered “bed rails”—without

distinguishing between upper and lower bed rails—as recommended medical equipment for WS

“to improve bed mobility.” AR at 10.

4 No. 59660-1-II

At some point after the bed rail assessment and follow-up visit, Little and Stephen Slack,

WS’s son, brought the upper bed rails that were previously installed on WS’s bed at home to

Vintage Years.

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