Haywood v. Rechen

696 N.E.2d 549, 45 Mass. App. Ct. 185
CourtMassachusetts Appeals Court
DecidedJuly 15, 1998
DocketNo. 97-P-0401
StatusPublished
Cited by1 cases

This text of 696 N.E.2d 549 (Haywood v. Rechen) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Haywood v. Rechen, 696 N.E.2d 549, 45 Mass. App. Ct. 185 (Mass. Ct. App. 1998).

Opinion

Flannery, J.

Twenty-one year old Alanna Joy Haywood, a student at Williams College (college), died at North Adams Regional Hospital in North Adams, Massachusetts, on January 11, 1993. On July 26, 1995, Mona L. Haywood, administratrix of the estate of Alanna Joy Haywood, filed a complaint alleging medical malpractice against the college and four of its employees, Roxanne Rechen, R.N., Patricia A. Austin, R.N., [186]*186Dorothy Johnson, R.N., and Daniel M. Sullivan, M.D. A tribunal was convened to evaluate the plaintiff’s claims pursuant to G. L. c. 231, § 60B,3 and it determined that the plaintiff’s offer of proof with respect to Dr. Sullivan, Nurse Rechen, Nurse Austin, Nurse Johnson, and the college was sufficient to raise a legitimate question of liability appropriate for judicial inquiry.

On March 27, 1996, the plaintiff moved to add as a defendant James T. Corkins, M.D., director of health services at the college, and to file an amended complaint. The motion was allowed on March 29, 1996. A second tribunal considered the plaintiff’s claims against the added physician and determined that the plaintiff’s offer of proof with respect to Dr. Corkins was insufficient to raise a legitimate question of liability appropriate for judicial inquiry. Therefore, in order to proceed with the claims against Dr. Corkins, the plaintiff had to post a bond within thirty days of the tribunal’s finding. See G. L. c. 231, § 60B. The plaintiff failed to file the bond, and Dr. Corkins moved to dismiss the action against him. On December 11, 1996, separate and final judgment was entered dismissing the plaintiff’s claims against Dr. Corkins pursuant to Mass.R.Civ. P. 54(b), 365 Mass. 821 (1974). The plaintiff appeals.

On appeal, the plaintiff contends that the tribunal erred in concluding that the offer of proof with respect to Dr. Corkins was insufficient to raise a legitimate question of liability appropriate for judicial inquiry. We affirm.

[187]*1871. Background. The following facts are taken from the plaintiffs offer of proof. Ms. Haywood entered the college as a freshman in 1989. Between September, 1989, and January, 1993, she often used the college dispensary when she was ill.

On January 10, 1993, at 6:30 a.m., Ms. Haywood went to the dispensary with complaints of foot, jaw, and throat pain. The impression was that she probably had a foot sprain and possible growth of wisdom teeth. She was told to return the next day or sooner, if needed. Ms. Haywood returned about six and one-half hours, later and was admitted to the dispensary. The nurse examined her head and ankle and noted that Ms. Haywood had a “strange affect.” The nurse administered codeine, without a doctor’s order.

Ms. Haywood’s condition steadily deteriorated and by 11:30 p.m. she complained that her whole body ached, she could not walk, and she was unable to open her jaw. She also had mental status changes, vomiting, and a fever. Dr. Sullivan was notified at 11:30 p.m. but did not come to examine Ms. Haywood that evening.

The following morning, between 5:10 a.m. and 5:30 a.m., Dr. Sullivan examined Ms. Haywood. This was done only after Ms. Haywood insisted, at 4:30 a.m., that she be taken to an emergency room. Dr. Sullivan gave her no medications but arranged for her to go to the hospital by campus security. Ms. Haywood arrived at North Adams Regional Hospital at approximately 6:20 a.m. She died two hours later. The autopsy report listed the cause of death as meningococcal septicemis with blood cultures positive for neisseria meningitides.

Dr. Rodney M. Wishnow and Dr. Robert Sundel, the plaintiff’s experts, whose affidavits were attached to the offer of proof, both opined that the negligence of the three nurses who attended Ms. Haywood during her in-patient stay at the college dispensary, and of Dr. Sullivan, were causally related to the death of Ms. Haywood, who required immediate care for her septic condition.

The plaintiff’s experts also opined that deficiency in Ms. Haywood’s medical records at the college contributed to her death. Ms. Haywood was under the care of Dr. Frederick G. Kantrowitz, a specialist in rheumatology and metabolic bone disease, for a systemic rheumatic illness from approximately June, 1991. In November, 1991, Dr. Kantrowitz wrote a letter to the “Department of Health” at the college advising that Ms. [188]*188Haywood was suffering from a systemic rheumatic illness. Moreover, he stated that she was anemic and leukopenic.

Dr. Wishnow stated that Dr. Kantrowitz’s report to the college regarding Ms. Haywood’s medical problems should have forewarned the medical personnel at the dispensary that Ms. Haywood probably had a greater than normal susceptibility to infection, with a diminished ability to overcome such infection if it occurred. Accordingly, both Dr. Wishnow and Dr. Sundel opined that Ms. Haywood’s reported condition should have been “flagged” in her records at the dispensary in some manner so that any health care provider would be made aware of her problem. Dr. Kantrowitz’s letter was retained in Ms. Haywood’s medical record, but it was not “flagged” therein. The experts concluded that the failure to “flag” Ms. Haywood’s file with the information about her condition was causally related to her death.

Nurse Johnson testified in her deposition that the college has a procedure for “flagging” students’ special health risks. These health risks are noted in red ink on the inside cover of students’ charts so that they are readily available to health care providers upon review of the charts. She explained that Dr. Corkins sees all students when they are admitted to the college, and if they have any underlying conditions, they are “put down right away.” Dr. Corkins would then instruct another person to do the flagging.

2. Sufficiency of the offer of proof as to Dr. Corkins. In accordance with G. L. c. 231, § 60B, the medical malpractice tribunal must determine if the plaintiff’s offer of proof contains evidence which, “if properly substantiated[,] is sufficient to raise a legitimate question of liability appropriate for judicial inquiry.” G. L. c. 231, § 60B. To raise a question of liability against a physician, the plaintiff’s offer of proof must show that “(1) a doctor-patient relationship existed; (2) the doctor did not conform to accepted medical standards in performing his duties with regard to the patient; and (3) damage resulted from this failure to conform.” Perez v. Bay State Ambulance & Hosp. Rental Serv., Inc., 413. Mass. 670, 676 (1992), citing Kapp v. Ballantine, 380 Mass. 186, 193 (1980).

“In evaluating a plaintiff’s offer of proof, the tribunal must apply a standard comparable to that which a trial judge would employ in determining whether to allow á defendant’s motion for a directed verdict.” St. Germain v. Pfeifer, 418 Mass. 511, [189]*189516 (1994),. citing Little v. Rosenthal, 376 Mass. 573, 578 (1978). Under this standard, “a medical malpractice tribunal must conclude that the plaintiff’s offer of proof raises a legitimate question of liability appropriate for judicial inquiry if ‘anywhere in the evidence, from whatever source derived, any combination of circumstances could be found from which a reasonable inference could be drawn in favor of the plaintiff.’ ”4 St. Germain v. Pfeifer, supra, quoting from Dobos v. Driscoll, 404 Mass. 634, 656, cert. denied sub nom. Kehoe

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696 N.E.2d 549, 45 Mass. App. Ct. 185, Counsel Stack Legal Research, https://law.counselstack.com/opinion/haywood-v-rechen-massappct-1998.