Daniels v. Hospital of Philadelphia College of Osteopathic Medicine

52 Pa. D. & C.4th 233, 2001 Pa. Dist. & Cnty. Dec. LEXIS 424
CourtPennsylvania Court of Common Pleas, Philadelphia County
DecidedJune 14, 2001
Docketno. 2450
StatusPublished

This text of 52 Pa. D. & C.4th 233 (Daniels v. Hospital of Philadelphia College of Osteopathic Medicine) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Philadelphia County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Daniels v. Hospital of Philadelphia College of Osteopathic Medicine, 52 Pa. D. & C.4th 233, 2001 Pa. Dist. & Cnty. Dec. LEXIS 424 (Pa. Super. Ct. 2001).

Opinion

KLEIN, J.,

I. SUMMARY

Plaintiff, Patricia Daniels, filed this lawsuit on behalf of her son, Roderick Sterling, who was bom prematurely at the Hospital of Philadelphia College of Osteopathic Medicine. Plaintiff claims that because of [235]*235hospital negligence, Roderick suffers from impaired cognitive and psychomotor functions.

Daniels attributes this harm to allegedly negligent observation and monitoring of the baby by hospital staff resulting in significant blood loss. Because of the blood loss, Roderick suffered acute anemia which lasted about a month. Roderick now suffers from deficiency of cognitive skills and he had problems with language development and psychomotor skills. Plaintiff attributes these problems to the acute anemia suffered while in the hospital.

To support this claim plaintiff offered the report of Dr. Adler as her expert witness. Dr. Adler opined that the problems that Roderick suffers from can be attributed to acute anemia. Although there is literature supporting the theory that the kind of deficits from which Roderick suffers can be caused by long-term iron deficient anemia, this is a different disease from the acute anemia from which Roderick suffered.

This court specifically asked for additional argument and briefing to hone in on the differences between the two types of anemia. After thorough review of the original and supplemental evidence, I granted an order precluding the testimony of Dr. Adler. This is because even after given the chance to supplement his report, Dr. Adler did not present evidence that there was sufficient generally accepted medical authority that acute anemia causes these kind of problems. Therefore, the requirements of Frye1 and Daubert2 were not met.

[236]*236Once Dr. Adler’s testimony was precluded, there was insufficient evidence to go to a jury, and the case was dismissed on summary judgment. Daniels is now appealing the summary judgment decision.

Daniels claims that the court erred in granting the hospital summary judgment because:

(1) Plaintiff claims that her expert witness causation testimony satisfies the requirements of Blum v. Merrell Dow Pharmaceuticals Inc., 564 Pa. 3, 764 A.2d 1 (2000) and that of Daubert and Frye. This is untrue. Dr. Adler’s theory is that Roderick’s acute anemia and absence of other problems could lead to the difficulties claimed. However, this theory is not supported by a significant number of medical professionals. Dr Adler did not offer any evidence that his theory was supported with respect to acute anemia. The article that Dr. Adler did rely upon dealt with the defects of long-term iron deficient anemia which is not the same as acute anemia suffered by the plaintiff, and he presented no other evidence relating to acute anemia. This is not merely an oversight, since the doctor was specifically asked to address the difference between the two types of anemia.

(2) Plaintiff’s second claim is that the trial court incorrectly read Dr. Adler’s report and the Blum case. Although Dr. Adler only uses one article, Daniels asserts that it was representative of the vast medical literature on the subject. This argument is without merit for the reason that even though the article cites 41 sources, these sources talk about the problems related to iron deficient anemia, not the acute disease from which Roderick suffered. The plaintiff presents no lit[237]*237erature or sources that support her theory when the problem is acute anemia following blood loss rather than long-term anemia.

(3)Plaintiff’s third claim is that the hospital: (a) failed to reference any body of scientific literature that stated that anemia does not cause cognitive and developmental delays, and (b) that the hospital failed to show that scientific literature relied on by Daniels’ expert was not generally accepted by the scientific community. This argument fails because the burden of proof is on the plaintiff, and the defendant has no burden to prove anything.

(4) Plaintiff’s fourth claim is that the court made factual determinations that should have been found by a jury. It is true that courts merely act as gatekeepers and should only decide if the mechanism of causation is accepted by the scientific community. However, it is the court’s job to decide if an expert witness’ opinion has achieved “general acceptance” in the medical community. I did not make any factual findings. I merely reviewed the record and articles presented by plaintiff to find they were devoid of any opinion stating that acute anemia causes these kinds of problems, and therefore that Dr. Adler’s theory did not exhibit the general acceptance standard that is required by the Blum IF test of scientific causation. Therefore, the testimony did not qualify to come in as expert testimony.

(5) Plaintiff’s last issue on appeal is that the court misinterpreted the standards of Blum and Frye. Blum held that the scientific methodology used by plaintiffs was flawed because they did not present any studies that established causation. Since in this case Daniels pre[238]*238sented the article which traced lowered hemoglobin to the developmental delays, Daniels alleges that it is irrelevant that the anemia is caused by iron deficiency or blood loss. Further, Daniel alleges that the court’s attempt to distinguish between the two is medically incorrect. This argument fails because although Daniels’ expert relied on the article on the iron deficient anemia, he did not establish a connection between the two types of anemia.

The arguments will be discussed in more detail below.

n. FACTS

Roderick Sterling was born four weeks premature. On July 20, 1992, while in the neonatal intensive care unit at Osteopathic Hospital, a nurse placed an umbilical vein line on him. Upon removal of it, the umbilical site was noted to be oozing blood. Plaintiff alleges negligent observation and monitoring which led to Roderick losing in excess of 25 percent of his blood volume through his umbilical cord in about 15 minutes.

Because of the blood loss, Roderick suffered acute anemia, which lasted about a month. However, at no time during the first six months of life did he suffer from an iron deficiency. Roderick now has a defect in cognitive skills, which is evident by his low I.Q. level of about 80. In addition, he had problems with language development and psychomotor skills.

An expert witness presented by Daniels, Dr. Adler, said that it was his opinion that the hemorrhage caused anemia and it in turn caused the harm complained of. Dr. Adler continued, saying that the increased harm and [239]*239prematurity is directly related to the development concerns and seizures that effect Roderick.

The defendant questioned whether Dr. Adler’s opinion that “anemia and low hemoglobin in infancy has significant and long-term effects on cognitive, psychomotor, and verbal skills,” was supported by members of the medical field. Dr. Adler filed a supplemental report in which he cited only one article. That article is “Effects of Iron Deficient Anemia on Cognitive Skills in Infancy and Childhood,” by Thomas Walter and others.

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Related

Daubert v. Merrell Dow Pharmaceuticals, Inc.
509 U.S. 579 (Supreme Court, 1993)
Mitzelfelt v. Kamrin
584 A.2d 888 (Supreme Court of Pennsylvania, 1990)
Blum v. Merrell Dow Pharmaceuticals, Inc.
764 A.2d 1 (Supreme Court of Pennsylvania, 2000)
Commonwealth v. Topa
369 A.2d 1277 (Supreme Court of Pennsylvania, 1977)
Ertel v. Patriot-News Co.
674 A.2d 1038 (Supreme Court of Pennsylvania, 1996)
Bergman v. United Services Automobile Ass'n
742 A.2d 1101 (Superior Court of Pennsylvania, 1999)
Frye v. United States
293 F. 1013 (D.C. Circuit, 1923)

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Bluebook (online)
52 Pa. D. & C.4th 233, 2001 Pa. Dist. & Cnty. Dec. LEXIS 424, Counsel Stack Legal Research, https://law.counselstack.com/opinion/daniels-v-hospital-of-philadelphia-college-of-osteopathic-medicine-pactcomplphilad-2001.