Dobbs v. United States

CourtDistrict Court, E.D. Arkansas
DecidedDecember 5, 2023
Docket4:20-cv-01192
StatusUnknown

This text of Dobbs v. United States (Dobbs v. United States) is published on Counsel Stack Legal Research, covering District Court, E.D. Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dobbs v. United States, (E.D. Ark. 2023).

Opinion

Case 4:20-cv-01192-LPR Document 50 Filed 12/05/23 Page 1 of 107

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS CENTRAL DIVISION

CRAIG DOBBS and PLAINTIFFS EILEEN DOBBS

v. Case No.: 4:20-cv-01192-LPR

UNITED STATES OF AMERICA DEFENDANT

MEMORANDUM OF DECISION

On October 7, 2020, Plaintiffs Craig and Eileen Dobbs filed a Complaint against the United

States of America under the Federal Tort Claims Act, alleging that Mr. Dobbs suffered a brain

hemorrhage as a result of negligent medical care by Dr. Diaa Bahgat.1 More specifically, the

Complaint alleges that: (1) during the laminectomy surgery performed by Dr. Bahgat, Mr. Dobbs

suffered a dural tear; and (2) Dr. Bahgat’s subsequent medical treatment of Mr. Dobbs—

particularly the placement of a drain near the dural tear site—was below the standard of care in

Arkansas and caused Mr. Dobbs to suffer a brain hemorrhage.2

The Court held a bench trial from November 29, 2022, through December 2, 2022.3 At

this trial, Plaintiffs pressed their right to monetary relief for the following categories of damages:

(1) Mr. Dobbs’s past and future physical pain and suffering; (2) his past and future mental pain

and anguish; (3) his past and future permanent physical impairment; (4) his past and future mental

impairment; (5) his past and future physical disfigurement; (6) his past and future medical, health

care, and attendant care expenses; (7) his out-of-pocket expenses; (8) his past and future loss of

1 See Compl. (Doc. 1) ¶¶ 6.1–7.2. 2 See id. At trial, the witnesses used the terms “dural tear” and “durotomy” interchangeably. For consistency, the Court will refer to the tear as a “dural tear.” 3 See Clerk’s Minutes (Docs. 37–39, 41). Case 4:20-cv-01192-LPR Document 50 Filed 12/05/23 Page 2 of 107

enjoyment of life; (9) the loss of consortium with his wife; and (10) Mrs. Dobbs’s loss of

consortium with her husband.4

After the Plaintiffs rested, the Government made a Motion for Judgment on Partial

Findings under Federal Rule of Civil Procedure 52(c).5 Parts of that Motion were easy to address.

For example, the Government argued that the Plaintiffs had failed to introduce any evidence that

Dr. Bahgat (1) negligently caused the dural tear, and (2) negligently repaired the dural tear.6

Plaintiffs’ counsel effectively conceded the points. She explained that Plaintiffs were not making

a claim that Dr. Bahgat was negligent in making the dural tear.7 She also explained that they were

not alleging that the dural-tear repair itself was negligent, except to the extent that Dr. Bahgat

“negligently left a drain in place in the absence of a complete repair.”8 Accordingly, and without

objection, the Court granted the Government’s Motion for Judgment on Partial Findings on the

two very specific issues raised by the Government.9

Other parts of the Government’s Motion for Judgment on Partial Findings were not so easy.

For example, with respect to Plaintiffs’ claims concerning the placement of a drain, the

Government argued that there had been no evidence to suggest that the use of a drain in the

circumstances of this case fell below the standard of care in Arkansas.10 The Government also

4 See Compl. (Doc. 1) ¶¶ 8.1, 8.2. At the start of the trial, Mr. Dobbs withdrew his claim for loss of earning capacity. See Tr. of Bench Trial (Doc. 45) at 20:15–20. And Mrs. Dobbs withdrew her claims for negligent infliction of emotional distress and for loss of household services. See id. at 20:21–21:7. 5 See Tr. of Bench Trial (Doc. 47) at 652:20–22. 6 See id. at 658:7–659:19. The Government made a Motion for Judgment on Partial Findings with respect to a third issue as well: that there was no evidence Dr. Bahgat had improperly delayed taking Mr. Dobbs for a re-exploration surgery. See id. But the Government withdrew this part of its Motion when Plaintiffs’ counsel explained that Plaintiffs were not making any claim for relief related to the delay in the re-exploration surgery. See id. at 662:11–22, 663:6– 15. Instead, this was merely a fact pled, not an independent allegation of wrongdoing. See id. 7 See Tr. of Bench Trial (Doc. 47) at 659:23–24. 8 Compl. (Doc. 1) ¶ 6.12. See also Tr. of Bench Trial (Doc. 47) at 660:3–8. 9 See Tr. of Bench Trial (Doc. 47) at 662:9–10. 10 See Tr. of Bench Trial (Doc. 47) at 654:8–657:7.

2 Case 4:20-cv-01192-LPR Document 50 Filed 12/05/23 Page 3 of 107

argued that there was not enough evidence to prove that the use of the drain was a “but-for” and

proximate cause of the brain hemorrhage.11 The Court denied those parts of the Motion because

the Court had heard evidence that could ultimately lead to the conclusion that Plaintiffs had proved

Dr. Bahgat’s decision to place the drain fell below the standard of care in Arkansas and caused the

injury at issue.12 At the conclusion of the trial, the Government again moved for Judgment on the

Findings on these issues.13 And the Court again denied the Government’s Motion.14

On December 19, 2022, the parties submitted post-trial proposed findings of fact and

conclusions of law. In accordance with Federal Rule of Civil Procedure 52(a), and after reviewing

the entire trial record, the Court makes the following findings of fact and conclusions of law as set

out below. As a threshold matter, however, the Court wishes to note several global points. First,

the Court makes all findings of fact in this case subject to the preponderance-of-the-evidence

standard.15 And Plaintiffs bear the burden of proof with respect to all findings. Second, the Court

notes that sometimes—but not always—it expressly discusses the evidence in the trial record that

is contrary to the Court’s ultimate finding. Whether or not the Court expressly discusses

conflicting or contrary evidence, the Court’s findings should be taken to imply that any such

conflicting evidence was overcome by the evidence supporting the particular fact found. Third, to

the extent the Court has erroneously designated any findings of fact as conclusions of law, they

11 See id. 12 See id. at 657:8–10. 13 See Tr. of Bench Trial (Doc. 48) at 885:6–11. 14 See id. at 885:17–18. 15 Although the Court may not always expressly state it, all medical opinions were given to a reasonable degree of medical certainty. The terms “certainty” and “probability” were used interchangeably at trial, but either term is appropriate and sufficient under Arkansas law. See Williamson v. Elrod, 348 Ark. 307, 311, 72 S.W.3d 489, 492 (2002).

3 Case 4:20-cv-01192-LPR Document 50 Filed 12/05/23 Page 4 of 107

should be deemed findings of fact.16 And any conclusions of law erroneously designated by the

Court as findings of fact shall be likewise deemed conclusions of law.17 Fourth, and finally, some

of the findings of fact (and maybe conclusions of law) in the liability section are relevant to the

issue of damages as well. The particular section of this Memorandum of Decision in which a

finding is made, or conclusion is drawn, does not affect the substance of this Memorandum of

Decision.

FINDINGS OF FACT – LIABILITY

1. During the bench trial, 11 witnesses provided testimony. Plaintiffs called

Dr. Christopher Taylor,18 Dr. Diaa Bahgat,19 Dr. Paul Moore,20 Dr. Arthur Joyce,21 Dr. Carl

16 See Ridings v. Maurice, 444 F. Supp.

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