Gregory Howland v. Ellen Rebecca Wadsworth

CourtCourt of Appeals of Georgia
DecidedOctober 9, 2013
DocketA13A0927
StatusPublished

This text of Gregory Howland v. Ellen Rebecca Wadsworth (Gregory Howland v. Ellen Rebecca Wadsworth) 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
Gregory Howland v. Ellen Rebecca Wadsworth, (Ga. Ct. App. 2013).

Opinion

SECOND DIVISION BARNES, P. J., MILLER and RAY, 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/

October 9, 2013

In the Court of Appeals of Georgia A13A0927. HOWLAND et al. v. WADSWORTH.

RAY, Judge.

Ellen Rebecca Wadsworth sued Gregory Howland, PA-C, Paul Paustian, M.D.,

and their employer, Georgia EM-I Medical Services, P.C. (the “defendants”),

asserting claims for ordinary negligence and gross negligence, alleging that the

defendants failed to provide her with necessary medical treatment while she was in

the emergency department of the Houston Medical Center.1 At trial, the defendants

moved for a directed verdict, claiming that OCGA § 51-1-29.5 applied to

Wadsworth’s claims because her cause of action arose out of the provision of

“emergency medical care” in a hospital emergency room and that Wadsworth failed

1 Although other defendants were named in the suit, the other defendants were dismissed pursuant to a consent order prior to trial. to prove gross negligence by clear and convincing evidence as required by OCGA §

51-1-29.5 (c). Wadsworth argued that the statute did not apply because the treatment

she received was not “emergency medical care” as defined by OCGA § 51-1-29.5 (a)

(5) and that, therefore, the jury should be allowed to consider ordinary negligence

under the preponderance of evidence standard. The trial court denied the motion for

directed verdict, finding that the evidence was sufficient to create a jury issue on

gross negligence. The court further found that the evidence created a jury issue as to

whether the medical care provided to Wadsworth constituted emergency medical care,

which would determine which standard of care and burden of proof would apply.

Consequently, the trial court charged the jury on both ordinary negligence and gross

negligence, along with the respective burdens of proof. The court further charged the

jury on the statutory definition of “emergency medical care” and instructed the jury

that their determination as to whether Wadsworth’s claims involved the provision of

emergency medical care would determine which standard of care and burden of proof

to apply. Ultimately, the jury applied the ordinary negligence standard of care and

returned a verdict in favor of Wadsworth in the amount of $5,000,000.

The defendants appeal, arguing that the trial court erred: (1) by allowing the

jury to determine, as a question of fact, whether Wadsworth’s claims arose out of the

2 provision of “emergency medical care” as defined by OCGA § 51-1-29.5 (a) (5); (2)

in failing to decide, as a matter of law, that the medical care provided to Wadsworth

constituted emergency medical care; (3) in denying their motion for directed verdict

based on Wadsworth’s failure to show gross negligence by clear and convincing

evidence; and (4) in providing confusing instructions to the jury concerning the

applicable standard of care and burden of proof. For the reasons that follow, we

affirm.

At the outset, we note that “[t]his Court reviews the judgment entered by the

trial court after approval of a jury verdict upon the any evidence test, absent any

material error of law.” (Citation and punctuation omitted.) Timmons v. Cook, 287 Ga.

App. 712, 712 (652 SE2d 604) (2007). Additionally, when a question of law is at

issue, “we owe no deference to the trial court’s ruling and apply a de novo standard

of review.” (citation omitted.) Artson, LLC v. Hudson, ____ Ga. App. ___ SE2d 68

(2013).

So viewed, the evidence shows that sometime in late November 2008,

Wadsworth began experiencing pain in her feet which appeared to be getting worse

each day. On the morning of November 27, 2008, Wadsworth noticed that her feet

3 were cold and that she was unable to warm them. As the pain in her feet had increased

to the extent that she could no longer walk, she decided to call 911.

An ambulance arrived and transported Wadsworth to the Houston Medical

Center’s emergency room. Prior to arriving at the emergency room, a paramedic had

assessed Wadsworth’s condition and noted that she had normal vital signs and normal

blood circulation in her legs. The paramedic obtained a brief medical history from

Wadsworth and noted that she had a history of diabetes and hypertension. Based on

his assessment of Wadsworth’s condition, the paramedic determined that she did not

require any treatment during her transport to the emergency room.

Upon her arrival at the Houston Medical Center’s emergency room, Wadsworth

was classified as a “level 4” patient, meaning that her condition was “non-urgent.”

Wadsworth was assigned a bed in “C-pod,” which is an area designated for the

examination and treatment of patients who are expected to be “in and out in 90

minutes or less.” The nurse that did the initial triage noted that Wadsworth was

complaining of significant pain in both feet that had increased over the past couple

of days and that it was hard for her to walk. The nurse performed a physical

assessment of Wadsworth and noted that her feet were cold to the touch, but that she

had “positive” or “palpable” pulses in her feet at the time.

4 Wadsworth was eventually examined by defendant Gregory Howland, a

physician assistant who worked in the emergency room of the Houston Medical

Center. Howland noted that Wadsworth was in a “moderate” amount of pain and

ordered her morphine, which succeeded in alleviating some of her pain. Howland

considered Wadsworth to be relatively stable during his examination, and he believed

that her status had improved while she was in the emergency room. Based on his

review of Wadsworth’s symptoms and past medical history of diabetes and

hypertension, Howland engaged in a differential diagnosis, which included

considering the possibilities of acute arterial occlusion (blocked arteries), deep vein

thrombosis (DVT), and cellulitis (infection). Howland ordered Wadsworth to undergo

a venous ultrasound exam, which ruled out the possibility of DVT. Howland noted

that Wadsworth’s feet were cool, rather than cold, and he attributed the coolness of

her feet to her diabetes. Although Howland noted a diminished pulse in Wadsworth’s

feet, he considered the pulse to be sufficient to rule out an acute arterial occlusion.2

2 An acute arterial occlusion (or complete arterial blockage) would constitute an emergency, because it can cause a heart attack, stroke, or loss of limb. A diminished pulse can be a sign of arterial insufficiency (or partial arterial blockage), which can be treated on a nonemergency basis. At trial, three of the defendants’ own expert witnesses testified that, in their opinion, Wadsworth did not have an acute arterial occlusion at the time she was in the emergency room on November 27, 2008.

5 However, Howland did not order an arterial ultrasound or any other diagnostic tests

to determine whether Wadsworth’s diminished pulse was caused by a partial arterial

blockage. Based on the results of a blood test which indicated that Wadsworth had

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Jackson v. Rodriquez
325 S.E.2d 857 (Court of Appeals of Georgia, 1984)
Restina v. Crawford
424 S.E.2d 79 (Court of Appeals of Georgia, 1992)
American Multi-Cinema, Inc. v. Walker
605 S.E.2d 850 (Court of Appeals of Georgia, 2004)
West v. BREAST CARE SPECIALISTS, LLC
659 S.E.2d 895 (Court of Appeals of Georgia, 2008)
Pottinger v. Smith
667 S.E.2d 659 (Court of Appeals of Georgia, 2008)
Timmons v. Cook
652 S.E.2d 604 (Court of Appeals of Georgia, 2007)
Carter v. Smith
669 S.E.2d 425 (Court of Appeals of Georgia, 2008)
Johnson v. Omondi
736 S.E.2d 129 (Court of Appeals of Georgia, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
Gregory Howland v. Ellen Rebecca Wadsworth, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gregory-howland-v-ellen-rebecca-wadsworth-gactapp-2013.