Carol Fluhr v. Anonymous Doctor 1

CourtIndiana Court of Appeals
DecidedMay 9, 2024
Docket23A-MI-01632
StatusPublished

This text of Carol Fluhr v. Anonymous Doctor 1 (Carol Fluhr v. Anonymous Doctor 1) is published on Counsel Stack Legal Research, covering Indiana Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Carol Fluhr v. Anonymous Doctor 1, (Ind. Ct. App. 2024).

Opinion

FILED May 09 2024, 8:44 am

CLERK Indiana Supreme Court Court of Appeals and Tax Court

IN THE

Court of Appeals of Indiana Carol Fluhr, Individually and as Personal Representative of the Estate of Ed Fluhr, Deceased, Appellant-Respondent/Plaintiff

v.

Anonymous Doctor 1, Anonymous Medical Group 1, Anonymous Doctor 2, Anonymous Medical Group 2, Anonymous Medical Center 1, Anonymous Doctor 4, and Anonymous Medical Center 2, Appellees-Third-Party Defendants

and Anonymous Doctor 3 and Anonymous Medical Group 3, Appellees-Petitioners/Defendants

and Amy L. Beard, Commissioner, Indiana Department of Insurance, Third-Party Respondent

Court of Appeals of Indiana | Opinion 23A-MI-1632 | May 9, 2024 Page 1 of 15 May 9, 2024 Court of Appeals Case No. 23A-MI-1632 Appeal from the Marion Superior Court The Honorable Gary L. Miller, Judge Trial Court Cause No. 49D03-2212-MI-41670

Opinion by Judge Weissmann Judges Mathias and Tavitas concur.

Weissmann, Judge.

[1] On April 28, 2020, during the early days of the global COVID-19 pandemic,

Carol Fluhr’s husband, Ed Fluhr, died of a stroke. Carol, individually and as

the personal representative of Ed’s estate, contends that the defendants

misdiagnosed Ed and delayed critical care, thereby contributing to his death.

Defendants moved for summary judgment on grounds that they were immune

from Carol’s complaint under Indiana’s COVID-19 immunity statute. The trial

court agreed. We affirm.

Facts1 [2] On March 6, 2020, Governor Holcomb issued Executive Order 20-02, declaring

1 We held oral argument in this case on April 4, 2024, and thank counsel for their excellent advocacy. We also thank the amici, the Indiana State Medical Association and the American Medical Association, for their helpful brief.

Court of Appeals of Indiana | Opinion 23A-MI-1632 | May 9, 2024 Page 2 of 15 a Public Health Emergency for the COVID-19 pandemic. The next month, on

April 23, EMTs brought Ed to Anonymous Medical Center 1 with symptoms of

nausea, vomiting, and a headache. While en route, EMTs also performed a

stroke assessment test on Ed that reported, at that time, no signs of a stroke.

Arriving at Medical Center 1, doctors initially thought that Ed had COVID-19

and ordered a test to confirm. Doctors also had Ed undergo a head CT scan,

which did not reveal any abnormalities. But while the COVID-19 test results

were still pending, Ed’s condition deteriorated enough that he was sedated and

transferred to Anonymous Medical Center 2.

[3] Doctors at Anonymous Medical Center 2 also suspected Ed of being COVID-

19 positive. At that time, about six weeks after Governor Holcomb’s executive

order, emergency COVID-19 protocols required placing patients suspected of

having COVID-19 in contact isolation. The protocols restricted health care

providers from performing comprehensive full-contact physical examinations

while patients were suspected to have COVID-19. But doctors could still

perform more cursory physical examinations. The protocols delayed a physical

exam of Ed by several hours.

[4] Ed’s initial exam did not raise any immediate concerns. But his medical chart

noted that a more thorough, full-contact exam would have been performed if

not for Ed’s suspected COVID-19 diagnosis. Ed then received two more

COVID-19 tests at Medical Center 2. All three tests ultimately came back

negative. After two days in Medical Center 2, doctors eventually diagnosed Ed

with a stroke, which was his eventual cause of death.

Court of Appeals of Indiana | Opinion 23A-MI-1632 | May 9, 2024 Page 3 of 15 [5] Carol filed a medical malpractice claim against the attending doctors and

associated medical centers (collectively, Defendants). She argued that

Defendants’ failure to adequately examine Ed when he arrived caused his

stroke to go undiagnosed and contributed to his death. Carol provided an

affidavit from an expert witness who stated that no “medical reason” prevented

Defendants from properly diagnosing and treating Ed’s stroke. Id. at 122.

[6] Before the medical malpractice process began, Defendants moved for a

preliminary determination that they were immune from Carol’s suit and, if the

trial court agreed, summary judgment on that basis.2 Defendants’ immunity

claim arose under a new statute, Ind. Code § 34-30-13.5-1, et seq., which gave

health care providers civil liability immunity for services rendered during the

COVID-19 emergency.

[7] As part of their affirmative defense, Defendants’ evidence conceded that more

“complete and comprehensive physical exam[s] could have been performed on

[Ed]” and that “more testing, evaluation, or treatment alternatives may have

resulted in other differential diagnoses being considered and/or ruled out.”

Appellant’s App. Vol. II, p. 75. But Defendants generally contended that the

2 Under Indiana’s Medical Malpractice Act (MMA), “before a party brings a medical malpractice action in an Indiana court, the MMA requires that the proposed complaint be presented to a medical review panel and that the panel render an opinion.” Ramsey v. Moore, 959 N.E.2d 246, 250 (Ind. 2012) (citing Ind. Code § 34- 18-8-4); but see Ind. Code § 34-18-11-1(a) (allowing a defendant to request an appropriate trial court to “preliminarily determine an . . . issue of law” before submitting the case to the medical review panel).

Court of Appeals of Indiana | Opinion 23A-MI-1632 | May 9, 2024 Page 4 of 15 care Ed received followed policies designed to limit the spread of a deadly

disease. The trial court granted Defendants’ motions for summary judgment.

Discussion and Decision [8] In reviewing a summary judgment ruling, “[w]e apply the same standard as the

trial court.” Shawa v. Gillette, 209 N.E.3d 1196, 1199 (Ind. Ct. App. 2023). The

party moving for summary judgment bears the initial burden to show that no

genuine issue of material fact exists. Id. Summary judgment is improper if the

moving party fails to meet this burden, or, if the burden is met, the nonmoving

party in turn establishes a genuine issue of material fact. Fox v. Barker, 170

N.E.3d 662, 665 (Ind. Ct. App. 2021). Only the evidence specifically designated

to the trial court will be considered. Ind. Trial Rule 56(. All factual inferences

are construed in the nonmoving party's favor. Id. at 665-66.

[9] “When the defendant is the moving party, the defendant must show that the

undisputed facts negate at least one element of the plaintiff's cause of action or

that the defendant has a factually unchallenged affirmative defense that bars the

plaintiff’s claim.” Sheets v. Birky, 54 N.E.3d 1064, 1069 (Ind. Ct. App. 2016).

Here, Defendants rely on the COVID-19 immunity statute as an affirmative

defense. See Haggerty v. Anonymous Party 1, 998 N.E.2d 286, 291 (Ind. Ct. App.

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

Related

Ramsey v. Moore
959 N.E.2d 246 (Indiana Supreme Court, 2012)
Bules v. Marshall County
920 N.E.2d 247 (Indiana Supreme Court, 2010)
Northern Indiana Public Service Co. v. Sharp
790 N.E.2d 462 (Indiana Supreme Court, 2003)
Butler v. City of Peru
733 N.E.2d 912 (Indiana Supreme Court, 2000)
Jarvis Drilling, Inc. v. Midwest Oil Producing Co.
626 N.E.2d 821 (Indiana Court of Appeals, 1993)
Miller v. Indiana Department of Workforce Development
878 N.E.2d 346 (Indiana Court of Appeals, 2007)
F.D. v. Indiana Department of Child Services
1 N.E.3d 131 (Indiana Supreme Court, 2013)
Plank v. Community Hospitals of Indiana, Inc.
981 N.E.2d 49 (Indiana Supreme Court, 2013)
Roebuck v. Mayo Clinic
536 P.3d 289 (Court of Appeals of Arizona, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
Carol Fluhr v. Anonymous Doctor 1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carol-fluhr-v-anonymous-doctor-1-indctapp-2024.