Christina Hoyt Hutto v. McNeil-ppc, Inc.

CourtLouisiana Court of Appeal
DecidedDecember 7, 2011
DocketCA-0011-0609
StatusUnknown

This text of Christina Hoyt Hutto v. McNeil-ppc, Inc. (Christina Hoyt Hutto v. McNeil-ppc, Inc.) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Christina Hoyt Hutto v. McNeil-ppc, Inc., (La. Ct. App. 2011).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

11-609

CHRISTINA HOYT HUTTO, ET AL.

VERSUS

MCNEIL-PPC, INC., ET AL.

**********

APPEAL FROM THE TWENTY-SEVENTH JUDICIAL DISTRICT COURT PARISH OF ST. LANDRY, NO. 04-C-0096-D HONORABLE DONALD WAYNE HEBERT, DISTRICT JUDGE

ELIZABETH A. PICKETT JUDGE

Court composed of Marc T. Amy, Elizabeth A. Pickett, and J. David Painter, Judges.

AFFIRMED.

Kathleen Ann Manning McGlinchey Stafford, PLLC 12th Floor, 601 Poydras Street New Orleans, LA 70130 (504) 586-1200 COUNSEL FOR DEFENDANT/APPELLANT: McNeil-PPC, Inc. Charles S. Weems, III Gold, Weems, Bruser, Sues & Rundell P. O. Box 6118 Alexandria, LA 71307-6118 (318) 445-6471 COUNSEL FOR DEFENDANT/APPELLANT: McNeil-PPC, Inc.

Robert W. Sparks Debra D. O’Gorman Patrick G. Broderick Michael E. Planell Dechert, LLP 1095 Avenue of the Americas New York, NY 10036 (212) 649-8756 COUNSEL FOR DEFENDANT- APPELLANT: McNeil-PPC, Inc.

J. Clemille Simon Barry L. Domingue Simon Law Offices P. O. Box 52242 Lafayette, LA 70505-2242 (337) 232-2000 COUNSEL FOR PLAINTIFFS/APPELLEES: Christina Hoyt Hutto Eric Hutto

Donald W. Washington Nadia de la Houssaye Jones, Walker, Waechter, Poitenvent, Carrѐre & Denѐgre, LLP P. O. Box 3408 Lafayette, LA 70502 (337) 262-9000 COUNSEL FOR DEFENDANT/APPELLEE: The Louisiana Patients Compensation Fund PICKETT, Judge.

The defendant drug manufacturer in this products liability/medical

malpractice case appealed a judgment that held it and the defendant health care

provider liable to the plaintiffs for the death of their infant daughter. The

defendant health care provider and the plaintiffs answered the appeal. For the

following reasons, we affirm the judgment.

FACTS

Brianna Hutto was born to Eric and Christina Hutto on July 31, 2002. Eric

and Christina were seventeen years of age and lived with Christina‟s mother,

Theresa Oliver, in St. Landry Parish. The morning of January 3, 2003, Brianna

was fussy and running a slight fever; she was vomiting, and her bowel movements

were not normal. Christina gave Brianna 0.8 ml of Infants‟ Tylenol®

Concentrated Drops (Infants‟ Tylenol®). When Brianna‟s fever did not subside

and her condition did not improve, Christina brought her to the emergency

department of Opelousas General Hospital (OGH). While waiting for Brianna to

be seen by a physician, Christina showed OGH emergency department personnel

the bottle of Infants‟ Tylenol® she had administered to Brianna that morning.

Brianna‟s 11:00 a.m. dose of 0.8 ml Infant‟s Tylenol® was noted on the Intake

sheet generated with Brianna‟s treatment that evening.

After Brianna was examined by the emergency physician, an OGH nurse

gave Christina written after-care instructions which instructed that Brianna be

given three-quarters of a teaspoon “Tylenol®.” Theresa questioned whether the

dose was appropriate for such a young infant, and the nurse left her and Christina.

The nurse returned and changed the instruction from three-quarters of a teaspoon to one teaspoon, explaining the higher dose would be more effective for Brianna‟s

weight.

Unbeknownst to Christina and Theresa, the nurse‟s instruction referred to

Children‟s Tylenol® not Infant‟s Tylenol® because OGH used Children‟s

Tylenol® exclusively. Christina and Theresa assumed the instruction referred to

the Infants‟ Tylenol® Christina used before bringing Brianna to the hospital

because she had shown the bottle to OGH personnel. At the time, OGH nurses, not

doctors, calculated the appropriate doses of acetaminophen. OHG‟s representative

testified that the nurse did not consult the doctor who treated Brianna when he

gave his “Tylenol®” dosing instruction. Infant‟s Tylenol® is approximately four

times more concentrated than Children‟s Tylenol®.

OGH had a written policy on addressing questions caregivers, like Christina

and Theresa, had about Tylenol® dosing. The policy required OGH personnel to

give the caregivers a Tylenol® dosing sheet. The dosing sheet was prepared and

distributed by McNeil; it identified four different Tylenol® products that are for

infants or children and specified the different dosing instructions for each product.

OGH‟s policy also required its personnel to circle the correct dose on the dosing

sheet to insure caregivers knew which product and how much product to

administer to the infant or child patient. OGH admitted that it violated its own

policy by not providing Christina and Theresa with a dosing sheet.

The Huttos testified that after leaving OGH, they administered one teaspoon

of Infants‟ Tylenol® to Brianna four times: 12:00 midnight to 1:00 a.m. January 4;

January 4, between 7:30 and 8:00 a.m. and again at approximately 8:00 p.m.; and

January 5 at 5:30 p.m. Eric gave Brianna Infants‟ Tylenol®, at 5:30 p.m. January

5. She continued to run a high fever and appeared lethargic, and he returned with

2 her to the OGH emergency department. Initially, OGH personnel informed Eric

there was no reason to admit Brianna. However, Eric‟s father had accompanied

Eric to OGH, and he insisted that she be admitted because of her condition.

On the morning of January 6, tests showed that Brianna had acetaminophen

toxicity. Mucomyst, the antidote for acetaminophen overdose, was given to

Brianna. After further testing showed that Brianna‟s liver had been damaged, she

was transported by helicopter to Children‟s Hospital in New Orleans. In New

Orleans, it was determined that Brianna needed a liver transplant to survive, and

she was transported to a liver transplant hospital in Omaha, Nebraska. The viral

illness for which Brianna was initially treated at OGH prevented a transplant from

being performed, and she died of liver failure secondary to acetaminophen toxicity

on January 8, 2003.

Eric and Christina filed two separate lawsuits: one against OGH and

Dr. Guy Godeaux for medical malpractice, as provided in the Louisiana Medical

Malpractice Act, La.R.S. 44:1299.41−49, for the erroneous Infants‟ Tylenol®

dosing instruction given to them and one against McNeil-PPC, Inc. (McNeil), the

manufacturer of Infants‟ Tylenol® for products liability, pursuant to the Louisiana

Products Liability Act (LPLA), La.R.S.9:2800.51−60. The lawsuits were

consolidated for trial. On March 1, 2010, OGH admitted liability and paid the

Huttos $100,000.00, pursuant to La.R. 40:1299.42. Dr. Godeaux was then

dismissed voluntarily on March 5, 2010. Due to OGH‟s admission of liability, the

Patients Compensation Fund (PCF) entered the case to defend the fund on the issue

of causation and damages. See La.R.S. 40:1299.44. The case proceeded to trial

against McNeil and the PCF.

3 The case was tried before a jury over six days from June 15 to 26, 2010.

After deliberating, the jury returned a verdict in which it indicated that neither the

label on Infants‟ Tylenol® nor the design of Infants‟ Tylenol® was defective;

however, it assessed 23% fault to McNeil. Finding the verdict internally

inconsistent, the trial court instructed the jury to continue deliberating to resolve

the inconsistency.

The jury did as instructed and, thereafter, returned a verdict finding the

labeling on Infants‟ Tylenol® was defective; it assessed 23% fault to McNeil, 70%

fault to OGH, 2% fault to Christina, and 5% to Theresa. In its verdict, the jury

awarded Christina and Eric each damages in the amounts of $1 million for mental

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