CAROLE MASO v. BRIAN ZEH

CourtCourt of Appeals of Georgia
DecidedFebruary 24, 2023
DocketA22A1290
StatusPublished

This text of CAROLE MASO v. BRIAN ZEH (CAROLE MASO v. BRIAN ZEH) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
CAROLE MASO v. BRIAN ZEH, (Ga. Ct. App. 2023).

Opinion

SECOND DIVISION RICKMAN, C. J., MILLER, P. J., and PIPKIN, J.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

February 24, 2023

In the Court of Appeals of Georgia A22A1289, A22A1290. ZEH et al. v. MASO et al.; and vice versa.

RICKMAN, Chief Judge.

This appeal and cross-appeal arise from a medical malpractice action filed by

Carole Maso, individually as surviving spouse and as executrix of the Estate of

Eugene Charles Maso (collectively, “Maso”). In Case No. A22A1289, defendants

Brian Zeh, M.D., Stephen Hammond, and Northside Anesthesiology Consultants,

LLC, (collectively the “Northside defendants”) appeal from the trial court’s order

denying Dr. Zeh’s motion for summary judgment. The Northside defendants contend

that the trial court erred by finding that the Physician Assistant Act (“PAA”), OCGA

§ 43-34-100 et seq., creates vicarious liability for physicians for the conduct of

physician assistants they supervise. In Case No. A22A1290, Maso cross-appeals from

the trial court’s order denying her motions to exclude testimony of two defense expert witnesses, arguing that the testimony of both witnesses should be excluded under

OCGA § 24-7-702. For the reasons explained below, we reverse in Case No.

A22A1289, and we affirm in part and reverse in part in Case No. A22A1290.

Maso’s complaint, as amended, alleged that her husband, Dr. Eugene Maso,

underwent an elective outpatient endoscopic retrograde cholangiopancreatography

(“ERCP”) procedure on June 18, 2018. The anesthesia staff for Dr. Maso’s procedure

included Dr. Zeh, an anesthesiologist, and Hammond, a physician assistant (“PA”).

According to Maso, her husband died as a result of inadequate respiratory and

ventilatory monitoring by Hammond.

Maso sued Hammond, Dr. Zeh, and their employer, Northside Anesthesiology

Consultants, LLC, for medical malpractice claims arising from the medical treatment

provided to her husband. Maso subsequently filed motions to exclude testimony from

two defense experts, which the trial court denied.

Dr. Zeh filed a motion to exclude vicarious liability testimony and for summary

judgment. The trial court denied Dr. Zeh’s motion, noting that because Maso had

voluntarily withdrawn her direct liability claims against Dr. Zeh and agreed that her

experts would not offer testimony regarding whether Georgia law provides a basis for

the imposition of vicarious liability against Dr. Zeh, the only remaining issue raised

2 by Dr. Zeh’s motion was whether he could be held vicariously liable for Hammond’s

alleged negligence. The trial court found that, although Dr. Zeh could not be held

vicariously liable under an actual agency theory, he was vicariously liable for

Hammond’s conduct under the PAA. The trial court certified its order for immediate

review. After this Court granted Dr. Zeh’s interlocutory application, the appeal in

Case No. A22A1289 followed. In Case No. A22A1290, Maso cross-appealed from

the trial court’s order denying her motions to exclude the testimony of the two

defense experts.

Case No. A22A1289

1. The Northside defendants contend that the trial court erred in denying Dr.

Zeh’s motion for summary judgment. Specifically, they argue that the trial court erred

in finding that the PAA creates vicarious liability for supervising physicians for the

medical acts of their PAs. We agree.

In 2009,

[t]he General Assembly enacted the [PAA] to encourage the more effective utilization of the skills of physicians by enabling them to delegate health care tasks to [PAs] where such delegation is consistent with the patient’s health and welfare. OCGA § 43-34-101 (b). Under this Act, a [PA] may be licensed to perform patients’ services for which the PA has been found qualified to perform by academic and practical

3 training. OCGA §§ 43-34-102 (5), 43-34-103 (a). The Act establishes an application procedure to be followed to obtain approval by the [Georgia Composite Medical Board], the board charged with overseeing PAs, for the performance of specific medical tasks set forth in the proposed PA’s job description. A PA is limited to those tasks set forth in the job description except when the task is performed under the direct supervision and in the presence of the physician utilizing the PA, OCGA § 43-34-105, in which case the [PA] may perform any work authorized for physicians that the assistant is competent to do.

(Citation and punctuation omitted.) Cardio TVP Surgical Associates v. Gillis, 272 Ga.

404, 404-405 (1) (528 SE2d 785) (2000).

OCGA § 43-34-102 (9) defines “primary supervising physician” as “the

physician to whom the board licenses a physician assistant pursuant to a board

approved job description and who has the primary responsibility for supervising the

practice of a physician assistant pursuant to that physician assistant’s job

description.” An “alternate supervising physician” is “a physician to whom a board

approved primary supervising physician has delegated the responsibility of

supervising a physician assistant who is licensed to that primary supervising

physician and who agrees to supervise the physician assistant for the primary

supervising physician and who is on record with the board.” OCGA § 43-34-102 (2).

4 OCGA § 43-34-109 governs the involvement of a supervising physician in a patient’s

care and provides as follows:

When a patient receives medical services from a physician assistant, the supervising physician’s involvement in the patient’s care, including patient evaluation and follow-up care by the supervising physician, shall be appropriate to the nature of the practice and the acuity of the patient’s medical issue, as determined by the supervising physician.

The PAA does not directly address the question of whether a supervising

physician is vicariously liable for the negligent acts of a PA. Maso’s argument that

the PAA confers vicarious liability on supervising physicians is based on OCGA §

43-34-103.

OCGA § 43-34-103 (a) (2) provides, in pertinent part:

In order to obtain approval for the utilization of a physician assistant, whether the utilization is in a private practice or through a public or private health care institution or organization, the licensed physician who will be responsible for the performance of such physician assistant shall submit an application to the board which shall include [evidence the PA is licensed, a job description in accordance with 43-34-102 (4); and a fee, if required].

OCGA §

Related

Daubert v. Merrell Dow Pharmaceuticals, Inc.
509 U.S. 579 (Supreme Court, 1993)
Cardio TVP Surgical Associates, P.C. v. Gillis
528 S.E.2d 785 (Supreme Court of Georgia, 2000)
Craigo v. Azizi
687 S.E.2d 198 (Court of Appeals of Georgia, 2009)
Emory-Adventist, Inc. v. Hunter
687 S.E.2d 267 (Court of Appeals of Georgia, 2009)
Dubois v. Brantley
775 S.E.2d 512 (Supreme Court of Georgia, 2015)
William D. Taylor, Jr. v. Cheryl Lynn Fields
797 S.E.2d 127 (Court of Appeals of Georgia, 2017)
Rudy Robles v. Patricia Yugueros
807 S.E.2d 110 (Court of Appeals of Georgia, 2017)
In the Interest of H. E. B.
695 S.E.2d 332 (Court of Appeals of Georgia, 2010)
Hendley v. Evans
734 S.E.2d 548 (Court of Appeals of Georgia, 2012)

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CAROLE MASO v. BRIAN ZEH, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carole-maso-v-brian-zeh-gactapp-2023.