Brumfield ex rel. Brumfield v. Langston

906 So. 2d 48, 2004 Miss. App. LEXIS 1106, 2004 WL 2711166
CourtCourt of Appeals of Mississippi
DecidedNovember 30, 2004
DocketNo. 2003-CA-00009-COA
StatusPublished

This text of 906 So. 2d 48 (Brumfield ex rel. Brumfield v. Langston) is published on Counsel Stack Legal Research, covering Court of Appeals of Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brumfield ex rel. Brumfield v. Langston, 906 So. 2d 48, 2004 Miss. App. LEXIS 1106, 2004 WL 2711166 (Mich. Ct. App. 2004).

Opinions

BRIDGES, P.J.,

for the Court.

¶ 1. On behalf of her son, Cody, Joan Brumfield sued Dr. LeDon Langston for medical malpractice. A jury sitting before the Pike County Circuit Court returned a verdict for Dr. Langston. Cody filed a motion for JNOV or, alternatively, for new trial. The circuit court denied Cody’s motions. Aggrieved, Cody appeals and asserts the following issues:

I.THE TRIAL COURT COMMITTED REVERSIBLE ERROR BY PREVENTING THE PLAINTIFF FROM CROSS-EXAMINING THE DEFENDANT IN THE PRESENCE OF THE JURY ABOUT MID-FORCEPS DELIVERY AND ALTERED MEDICAL RECORDS.
II. THE TRIAL COURT COMMITTED REVERSIBLE ERROR BY ALLOWING CUMULATIVE TESTIMONY FROM EXPERT WITNESSES ON THE ISSUES OF LIABILITY, CAUSATION, AND INJURY OVER THE PLAINTIFF’S OBJECTIONS.
III. THE TRIAL COURT COMMITTED REVERSIBLE ERROR BY DENYING PLAINTIFF’S MOTION FOR A NEW TRIAL.

¶ 2. Finding no error, we affirm.

FACTS

¶ 3. Cody Brumfield was born on May 19, 1989. Cody’s mother, Joan, experienced labor complications during delivery. In particular, Cody’s shoulders lodged behind Joan’s pelvis. The medical community uses the term “shoulder dystocia” to describe that event.1 Dr. LeDon Langston attended Cody’s delivery. Dr. Langston dislodged Cody’s shoulder from Joan’s pelvis and Cody arrived into this world without further complication. However, Cody was born with a damaged right arm. At that time, it was unknown whether Cody’s arm would develop normally. Time would reveal that Cody had a condition known as Erb’s Palsy. Erb’s Palsy occurs when the cervical nerves in an unborn baby’s shoulder stretch, resulting in nerve damage. The condition manifests as an underdeveloped arm.

[50]*50¶ 4. In May of 1997, Cody filed Ms complaint through Joan. In his complaint, Cody alleged that Dr. Langston negligently caused him to suffer Erb’s Palsy. Dr. Langston denied that he was negligent. The matter proceeded to. trial before the Pike County Circuit Court.

¶ 5. At trial, Cody presented three witnesses. Joan testified that when she gave birth to Cody, she had high blood pressure and diabetes. Further, Dr. Langston used forceps to pull Cody down but did not ask her about a Cesarean delivery, commonly called a C-Section. Cody, a large baby, weighed nine pounds and fifteen ounces. Cody’s shoulder was black and blue, limp, and “twisted in.” Cody’s arm never got better, but he was able to use it some.

¶ 6. Cody called Dr. Bernadette Sherman to testify as an expert witness. Dr. Sherman consulted Cody’s medical records and opined on the process of Cody’s delivery. Dr. Sherman noted that Joan was a large patient. The presence of diabetes and high blood pressure made Joan a high-risk patient. During labor, Cody “stayed high.” That meant that Cody did not descend down the birth canal at the normal rate. Dr. Sherman testified that when a baby “stays high” a complication might result.

Dr. Sherman went on to testify that shoulder dystocia is not common but there are indicators of that risk. According to Dr. Sherman, diabetics have large babies. That Joan was a diabetic is why Cody’s shoulder stuck. Further, when a baby does not come down, a physician should perform a C-Section. Dr. Sherman concluded that Dr. Langston breached the standard of care when he performed a vaginal delivery instead of a C-Section.

¶ 7. On cross-examination, Dr. Sherman agreed that shoulder dystocia is always dangerous and cannot be predicted. Further, she admitted that a C-Section strategy is not a good way to prevent shoulder dystocia. Finally, Dr. Sherman stated that she had no criticism of how Dr. Lang-ston used forceps. Rather, her criticism is that they were used when a C-Section was appropriate.

¶ 8. Cody ended his case-in-chief after he testified on his own behalf. Dr. Lang-ston presented a motion for directed verdict, but the circuit court demed that motion. Dr. Langston then argued his casein-chief. He testified on his own behalf and followed up with an expert witness.

¶ 9. Dr. Langston testified as an expert witness. He testified that there are three types of vaginal delivery: (1) spontaneous delivery in which the mother needs no assistance; (2) vacuum delivery in which suction aids the baby’s descent through the birth canal; and (3) forceps delivery. When a forceps delivery is necessary, the forceps are applied to the baby’s head so that the mother does not have to push for long periods.

¶ 10. In Joan’s case, Dr. Langston testified that a C-Section was never necessary but he did use forceps to reduce the second stage of labor. Once Cody’s head delivered, Dr. Langston removed the forceps. Although a baby usually delivers easily at that point, Cody’s shoulders were larger than his head and Cody’s shoulders lodged behind Joan’s pelvis. Dr. Langston said that many complications can result once that happens. To free a baby who experiences this, a physician first applies pressure to the mother’s pubic bone. When Dr. Langston did, Cody did not dislodge. A physician’s second option is to increase the size of the birth canal. Likewise, that did not free Cody. Finally, a physician should apply the “McRobert’s procedure” by which the physician pushes the mother’s knees towards her chest. When Dr. Langston performed the McRo-[51]*51bert’s procedure, Cody dislodged and delivered. Dr. Langston testified that C-Section is a last resort. Especially in Joan’s case, due to Joan’s having signed documents by which she detailed that her faith as a Jehovah’s witness forbid the possibility of her receiving a blood transfusion under any circumstance, even if necessary to save her life.

1111. During cross-examination, Cody’s counsel attempted to question Dr. Lang-ston about some of Joan’s medical records in which Dr. Langston altered an entry detailing a “mid-forceps” delivery. Dr. Langston crossed out “mid-forceps” and wrote “low-forceps” instead. When Cody’s counsel attempted to ask Dr. Langston about the alteration, Dr. Langston’s attorney objected and the trial court excused the jury. After some debate, the court determined that according to Cody’s casein-chief, the issue was whether Dr. Lang-ston was negligent in performing a vaginal delivery instead of a C-Section.

¶ 12. Dr. Langston’s attorney argued that the line of questioning at issue inferred that Dr. Langston used forceps to attempt to pull Cody free after Cody’s shoulders became trapped. Further, the facts did not suggest that set of events. Rather, Dr. Langston pulled Cody down the birth canal and stopped after Cody’s head delivered. It was at that point that Cody’s shoulders lodged behind Joan’s pelvis. The circuit court concluded that because Cody had presented his case-in-chief and failed to assert that Dr. Langston was negligent in the manner he applied the forceps, it was improper to assert that such was the case during Dr. Langston’s case-in-chief.

¶ 13. After Dr. Langston concluded his testimony, he called Dr. James Martin as an expert witness. Dr. Martin testified that it was appropriate to deliver Cody vaginally. At that point, Cody’s counsel objected and argued that Dr. Martin’s testimony was cumulative and, accordingly, improper. The circuit court overruled the objection.

¶ 14. Dr. Martin went on to testify that predicting shoulder dystocia is impossible. However, he opined that Dr. Langston managed it appropriately and was not negligent. Finally, Dr. Martin testified that under the circumstances a C-Section would have been improper.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Fisher v. State
690 So. 2d 268 (Mississippi Supreme Court, 1996)
Evans v. State
725 So. 2d 613 (Mississippi Supreme Court, 1997)
Watson v. State
848 So. 2d 203 (Court of Appeals of Mississippi, 2003)
Thompson MacHinery Commerce v. Wallace
687 So. 2d 149 (Mississippi Supreme Court, 1997)
Starcher v. Byrne
687 So. 2d 737 (Mississippi Supreme Court, 1997)

Cite This Page — Counsel Stack

Bluebook (online)
906 So. 2d 48, 2004 Miss. App. LEXIS 1106, 2004 WL 2711166, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brumfield-ex-rel-brumfield-v-langston-missctapp-2004.