Dobson v. Sears

CourtCourt of Appeals of North Carolina
DecidedNovember 19, 2024
Docket24-277
StatusPublished

This text of Dobson v. Sears (Dobson v. Sears) is published on Counsel Stack Legal Research, covering Court of Appeals of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dobson v. Sears, (N.C. Ct. App. 2024).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA24-277

Filed 19 November 2024

Cabarrus County, No. 21CVS2879

THE ESTATE OF JAMES STEVENSON DOBSON and SHEILA DOBSON, Individually, Plaintiffs,

v.

DEBORAH E. SEARS, R.N., MONIQUE M. ELLIS, R.N., ABIGAIL M. MAYTON, and THE CHARLOTTE-MECKLENBURG HOSPITAL AUTHORITY, a North Carolina Hospital Authority, d/b/a ATRIUM HEALTH, CAROLINAS HEALTHCARE SYSTEM, CAROLINAS MEDICAL CENTER NORTHEAST, and CAROLINAS HEALTHCARE SYSTEM NORTHEAST, Defendants.

Appeal by plaintiffs from judgment entered 6 October 2024 by Judge R. Stuart

Albright in Cabarrus County Superior Court. Heard in the Court of Appeals 24

September 2024.

The Law Office of Christopher A. Walker, PLLC, by Christopher A. Walker, for the plaintiffs-appellants.

Parker Poe Adams & Bernstein LLP, by Chip Holmes and Jessica C. Dixon, for the defendants-appellees.

Huff Powell & Bailey, PLLC, by Katherine Hilkey-Boyatt and Jonathan Earnest, for the defendants-appellees.

Beth Reeves, for the defendants-appellees.

TYSON, Judge.

James Steven Dobson, a fifty-eight-year-old man, had recently undergone

brain surgery to remove a malignant tumor. He fell while recovering at his home. DOBSON V. SEARS

Opinion of the Court

After being taken to the hospital and admitted as a patient, he fell again and

subsequently died. His wife, both individually and as Executrix of her husband’s

estate, sued the hospital system, two nurses, and one certified nursing assistant for

medical malpractice and loss of consortium. The trial court granted summary

judgment and dismissed the claims after striking portions of an expert witness’s

affidavit and excluding the expert witness’s testimony. Plaintiffs appeal. We affirm.

I. Background

Sheila Dobson (“Wife” or “Executrix”) was married to James Dobson

(“Decedent”). Decedent was born on 31 July 1960. Decedent was diagnosed with

Grade III Anaplastic Astrocytoma, an aggressive brain cancer. He underwent a left

frontotemporal craniotomy surgery to remove the tumor at the Charlotte

Mecklenburg Hospital Authority (“CHMA”) on 13 August 2018.

Decedent was released from a CHMA rehabilitation hospital on 5 September

2018, but he needed assistance and supervision while bathing, dressing, and

toileting, and for bed-to-chair transfers. Decedent was able to walk 500 feet with no

assistive devices and minimal supervision.

Five days after being released from the rehabilitation center, Decedent fell off

the bottom two steps of his front porch. Decedent fell face first on his right side and

did not attempt to catch himself. He had abrasions on the right side of his face and

his right shoulder. Emergency Medical Services arrived at 4:56 p.m. and transported

him to CHMA’s hospital in Concord.

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While at the hospital, Decedent reported he was getting up from sitting on the

porch, began to have visual changes, felt dizzy, and fell forward. Decedent presented

at the emergency room as a code trauma and underwent multiple images. His CT

scan revealed no acute abnormalities were present.

Decedent was admitted to the hospital at 7:45 p.m. with his Wife present.

Deborah Sears (“Sears”), a Registered Nurse (“RN”), was assigned to Decedent’s care.

She evaluated him as scoring 125 on the Morse Fall Risk scale at 10:14 p.m. She

noted Decedent was wearing a Fall Risk armband, and she implemented the following

precautions: ensuring adequate room lighting, keeping the patient’s bed in a low

position, and placing the call device and personal items within the patient’s reach.

Sears also instructed Decedent to only get out of bed with assistance. Both Decedent

and Wife indicated they understood Sears’ instructions.

Monique Ellis (“Ellis”) and Abigail Mayton (“Mayton”) were also assigned to

care for Decedent. Ellis is also a RN, and Mayton is a certified nursing assistant

(“CNA”). Mayton checked on Decedent during her rounds at 9:09 p.m. and 11:00 p.m.

on the evening of 10 September 2018, and at 1:12 a.m. on the morning of 11

September 2018. During these rounds, Mayton documented the following

environmental safety precautions had been implemented: “Adequate room lighting,

bed in low position, call device within reach, encourage handrail/safety bar use,

encourage personal mobility support item use, encourage sensory support item use,

non-slip footwear, personal items within reach, sensory aids within reach, traffic path

-3- DOBSON V. SEARS

in room free of clutter, wheels locked.”

At approximately 1:25 a.m. on 11 September 2018, thirteen minutes after

Mayton’s last round, Ellis responded to Decedent’s hospital room. Decedent had

fallen and suffered a laceration above his left eye and a laceration on his left elbow.

Ellis documented Wife was present in the room when her husband had fallen, and

she told Ellis she had “heard a loud thud and he hit the floor.”

The on-call physician tended to Decedent’s lacerations and ordered a head CT

scan immediately. The CT scan showed no changes or abnormalities. After the CT

scan, Decedent was returned to his room around 2:30 a.m. The medical record reveals

a bed alarm was placed on Decedent’s bed after his fall at the hospital. A bed alarm

was not mentioned in the prior records.

A subsequent MRI scan taken four days later, on 15 September 2018, revealed

a fluid collection over Decedent’s left cerebral convexity had slightly increased in size.

Decedent was discharged on 28 September 2018, but he continued to decline

neurologically. He was unable to receive radiation or chemotherapy, and he died on

13 June 2019 from complications due to recurrent astrocytoma.

Plaintiff, individually and as Executrix of Decedent’s estate (collectively

“Plaintiffs”), filed a complaint on 23 August 2023 against CHMA, Sears, Mayton, and

Ellis (collectively “Defendants”). Plaintiffs did not allege Decedent’s fall at the

hospital had caused his death. Rather, Plaintiffs alleged Sears, Mayton, and Ellis

were negligent pursuant to N.C. Gen. Stat. § 90-21.1(2)(a) (2023) by failing to activate

-4- DOBSON V. SEARS

Decedent’s bed alarm after he was assessed to be a high fall risk according to the

Morse Fall Risk scale and failing to consider and utilize other fall risk precautions.

The complaint alleged the acts of Sears, Mayton, and Ellis “are imputed to their

employer,” CHMA, and CHMA is vicariously liable. Plaintiffs contended “[a]s a direct

and proximate result of the joint and concurrent negligence” by Defendants,

“Decedent fell out of his hospital bed, suffered disfigurement indicated by a gash

requiring staples, neurological decline, [and] incurred a longer hospital stay and

medical bills.” Plaintiffs further alleged Defendants were grossly negligent, and

sought compensatory and punitive damages.

Plaintiffs also filed a corporate negligence claim pursuant to N.C. Gen. Stat.

§ 90-21.1(2)(b) (2023). Plaintiffs alleged the hospital or nurse administrator should

have advocated for Decedent by recommending the implementation of additional

safety interventions for the patient. Wife also asserted a claim for loss of consortium.

CHMA, Ellis, and Mayton filed motions to exclude the expert testimony of

Plaintiffs’ tendered expert, Natalie Mohammed, RN, and for summary judgment on

31 August 2023.

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