Charles W. Freeman v. Ltc Health Care of Statesboro Inc. D/B/A Westwood Nursing Center

CourtCourt of Appeals of Georgia
DecidedNovember 18, 2014
DocketA14A1404
StatusPublished

This text of Charles W. Freeman v. Ltc Health Care of Statesboro Inc. D/B/A Westwood Nursing Center (Charles W. Freeman v. Ltc Health Care of Statesboro Inc. D/B/A Westwood Nursing Center) 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
Charles W. Freeman v. Ltc Health Care of Statesboro Inc. D/B/A Westwood Nursing Center, (Ga. Ct. App. 2014).

Opinion

FOURTH DIVISION BARNES, P. J., DILLARD AND MCFADDEN, JJ.

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. http://www.gaappeals.us/rules/

November 18, 2014

In the Court of Appeals of Georgia A14A1404. FREEMAN et al. v. LTC HEALTHCARE OF STATESBORO, INC. d/b/a WESTWOOD NURSING CENTER et al.

MCFADDEN, Judge.

Hospice patient Mary L. Freeman died shortly after arriving at Westwood

Nursing Center, a long-term care facility. Her husband, Charles W. Freeman, acting

individually and as administrator for her estate (collectively, “Freeman”), brought a

malpractice action against several defendants including LTC Healthcare of

Statesboro, Inc. d/b/a Westwood Nursing Center (“Westwood”), the appellee in this

case. The trial court granted summary judgment to Westwood on the ground that

Freeman had not pointed to evidence that Mrs. Freeman’s death had been caused by

the alleged breaches in the standard of care. In so ruling, the trial court declined to

consider the expert opinion testimony of a nurse, concluding that she was not competent to opine on causation. We decline to adopt a “bright line” rule that nurses

may never testify to causation in medical malpractice cases, but we nevertheless

affirm the trial court’s grant of summary judgment because the evidence shows that

the nurse’s causation opinion in this case fell outside her realm of expertise.

To prevail on a motion for summary judgment, the moving party must

demonstrate that there is no genuine issue of material fact and that the party is entitled

to judgment as a matter of law. OCGA § 9-11-56 (c); Cowart v. Widener, 287 Ga.

622, 623 (1) (a) (697 SE2d 779) (2010).

A defendant may do this by either presenting evidence negating an essential element of the plaintiff’s claims or establishing from the record an absence of evidence to support such claims. . . . Where a defendant moving for summary judgment discharges this burden, the nonmoving party cannot rest on its pleadings, but rather must point to specific evidence giving rise to a triable issue.

Cowart, 287 Ga. at 623 (1) (a) (citations and punctuation omitted). We review a grant

of summary judgment de novo and construe the evidence, and all reasonable

conclusions and inferences drawn from it, in the light most favorable to the

nonmovant. Abdel-Samed v. Dailey, 294 Ga. 758, 760 (1) (755 SE2d 805) (2014).

2 So viewed, the evidence shows that in February 2003, Mrs. Freeman underwent

surgery to remove a benign brain tumor. She experienced serious complications

following the surgery including quadriplegia, and she had to have a tracheostomy

tube inserted.

On March 19, 2003, Mrs. Freeman was transferred from the hospital to

Westwood, arriving there around 2 p.m. The medical orders accompanying her

transfer instructed, among other things, that she receive albuterol treatments, that her

oxygen level be monitored, and that her tracheostomy tube be suctioned. Westwood’s

medical records reflect that at 4 p.m. Mrs. Freeman was given a feeding tube, but they

do not reflect that she received any other care that afternoon or evening.

Shortly before midnight, a Westwood nurse noticed that Mrs. Freeman was in

distress; she had “frothy mucous coming from her mouth and trach [sic],” was “non-

responsive,” and had “no blood pressure and a faint pulse.” In the early morning of

March 20, Mrs. Freeman died of respiratory failure.

In support of his malpractice claims against Westwood, Freeman presented the

expert opinion of Donna Jones, a registered nurse. In her affidavit and deposition

testimony, Jones opined that Westwood had breached the applicable standard of care

by: failing to follow the medical orders for Mrs. Freeman’s care, including failing to

3 provide albuterol treatments, tracheostomy suctioning, and oxygen monitoring;

failing to thoroughly assess Mrs. Freeman’s condition upon her admission; and failing

to assess, treat, report and document any changes to her condition. Jones opined that,

based upon a reasonable degree of medical probability, had [Westwood’s] nursing staff met the standard of care for nurses caring for quadriplegic patients with tracheostomy tubes when Mrs. Freeman was in [Westwood’s] care, this would have significantly altered Mrs. Mary Freeman’s treatment and prevented her death from respiratory failure[.]

Westwood sought summary judgment on the ground that there was an absence

of evidence showing that the alleged breaches of the standard of care proximately

caused Mrs. Freeman’s death. The trial court agreed, holding that, while Jones was

competent to give an opinion on whether Westwood breached the applicable standard

of care, she was not competent to give an opinion on causation. Accordingly, the trial

court granted summary judgment to Westwood.

To recover for medical malpractice, a plaintiff must demonstrate, to a

reasonable degree of medical probability, that a breach of the applicable standard of

care proximately caused the plaintiff’s injury. Zwiren v. Thompson, 276 Ga. 498, 499,

503 (578 SE2d 862) (2003); Berrell v. Hamilton, 260 Ga. App. 892, 896 (581 SE2d

398) (2003). The element of causation must be established through expert testimony

4 because the question of whether the alleged professional negligence caused the plaintiff’s injury is generally one for specialized expert knowledge beyond the ken of the average layperson. Using the specialized knowledge and training of his field, the expert’s role is to present to the jury a realistic assessment of the likelihood that the defendant’s alleged negligence caused the plaintiff’s injury.

Zwiren, 276 Ga. at 500-501(citations and punctuation omitted); accord Knight v.

Roberts, 316 Ga. App. 599, 604 (1) (a) (730 SE2d 78) (2012).

Pointing to decisions from other jurisdictions, Westwood invites us to adopt

what amounts to a “bright line” rule precluding nurses from giving expert opinions

on causation in medical malpractice cases. We find such a “bright line” rule

unnecessary, because Georgia law provides a framework for considering such expert

opinions on a case-by-case basis. “Georgia law . . . does not mandate that only

medical doctors be permitted to testify regarding medical issues; others with certain

training and experience may testify on issues within the parameters of their

experience.” Sinkfield v. Oh, 229 Ga. App. 883, 885 (495 SE2d 94) (1997) (citations

and punctuation omitted) (holding trial court erred in excluding witness educated in

pharmacology and toxicology from testifying in medical malpractice case that

defendant doctor’s prescription of medication was “predominate major contributing

5 factor to the demise of [plaintiff’s] fetus”). See also Hankla v. Jackson, 305 Ga. App.

391, 398 (2) (b) (699 SE2d 610) (2010) (holding trial court did not err in allowing

biomechanical engineer to testify in medical malpractice case about “the myriad

causes of brachial plexus injuries in general, the normal forces exerted by a mother

and birth attendants during labor and delivery, and the current medical literature

regarding causation of this type of injury”). This rule extends to a licensed registered

nurse testifying as an expert within the areas of her expertise. McCormick v. Avret,

246 Ga. 401 (271 SE2d 832) (1980); Hyde v.

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Avret v. McCormick
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578 S.E.2d 862 (Supreme Court of Georgia, 2003)
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Cowart v. Widener
697 S.E.2d 779 (Supreme Court of Georgia, 2010)
Hankla v. Jackson
699 S.E.2d 610 (Court of Appeals of Georgia, 2010)
Abdel-Samed v. Dailey
755 S.E.2d 805 (Supreme Court of Georgia, 2014)
Rainwater v. State
436 S.E.2d 772 (Court of Appeals of Georgia, 1993)
Knight v. Roberts
730 S.E.2d 78 (Court of Appeals of Georgia, 2012)

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Charles W. Freeman v. Ltc Health Care of Statesboro Inc. D/B/A Westwood Nursing Center, Counsel Stack Legal Research, https://law.counselstack.com/opinion/charles-w-freeman-v-ltc-health-care-of-statesboro-inc-dba-westwood-gactapp-2014.