In re Medical Review Panel of Aych

715 So. 2d 613, 1998 La. App. LEXIS 1737, 1998 WL 352807
CourtLouisiana Court of Appeal
DecidedJune 17, 1998
DocketNo. 97-CA-1570
StatusPublished

This text of 715 So. 2d 613 (In re Medical Review Panel of Aych) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Medical Review Panel of Aych, 715 So. 2d 613, 1998 La. App. LEXIS 1737, 1998 WL 352807 (La. Ct. App. 1998).

Opinion

h MURRAY, Judge.

Janice Aych appeals the judgment of the trial court rendered in favor of Dr. Mitchell A. Pierce, dismissing her dental malpractice action against him. She assigns as error the trial court’s failure to instruct the jury on La.Rev.Stat. 40:1299.131, relating to informing patients of general risks associated with dental treatment, and to include the issue of informed consent on the jury interrogatory form. Athough we find that the jury should have been charged on Dr. Pierce’s duty under La.Rev.Stat. 40:1299.131, we do not find that the failure to do so precluded its reach[614]*614ing a verdict based on the law and facts. We, therefore, affirm the judgment of the trial court.

Approximately 17 days after having an abscessed tooth extracted by Dr. Pierce in New Orleans, Ms. Aych suffered a stroke. Following rehabilitation in California, where she had moved prior to the stroke, Ms. Aych returned to New Orleans. She was treated at LSU Medical Center, where she eventually underwent surgery to replace the mitral valve of her heart. It has been determined that the ^stroke and destruction of Ms. Aych’s mitral valve were caused by subacute bacterial endocarditis. Endocarditis is an infection of the heart, generally of a valve. Subacute bacterial endocarditis takes longer to cause damage because the bacteria involved is usually less potent. Acute bacterial endocarditis progresses much more rapidly because the damage causing bacteria is more virile and aggressive. Ms. Aych filed this malpractice action against Dr. Pierce, contending that he deviated from the standard of care by failing to advise her of the dangers tooth extraction posed to someone, such as she, with a heart murmur, and failing to pre-treat her with antibiotics. She alleged that her stroke and the destruction of her mitral valve were caused by Dr. Pierce’s malpractice.

The jury found that Dr. Pierce had not deviated from the appropriate standard of care in his treatment of Ms. Aych. Judgment was entered in accordance with the verdict, dismissing the malpractice action.1 Ms. Ayeh’s motion for new trial was denied, and this appeal followed.

Ms. Aych argues that the trial court erred when it failed to instruct the jury regarding Dr. Pierce’s duty under La.Rev.Stat. 40:1299.131, dealing with informed consent to dental treatment, and to include a jury interrogatory asking if she had given an informed consent to the tooth extraction.

Dr. Pierce counters that the trial court correctly found that this was not an informed consent case. In addition, he argues that, notwithstanding the jury charge, Ms. Aych failed to satisfy her burden of proving that the extraction performed by him was more probably than not the cause of her illness and related complications.

\ ¿DISCUSSION:

In order to prevail on her claim for damages based on Dr. Pierce’s treatment without informing her of the risks associated with that treatment she had to prove, by a preponderance of the evidence, that Dr. Pierce failed to disclose to her the risk of death, brain damage, quadriplegia, paraplegia, the loss of function of an organ or limb associated with having her tooth extracted, if dentists with training and experience similar to his would have made the disclosure under similar circumstances; that the undisclosed risk occurred; and that a reasonably prudent person in her position would not have had the tooth extraction if properly informed. La.Rev.Stat. 40:1299.131 E.

There is no question that Dr. Pierce did not inform Ms. Aych of either the general risks associated with a tooth extraction or the specific risk that procedure posed for a person with a heart murmur. Dr. Pierce claims that Ms. Aych did not inform him that she had a heart murmur, therefore, he had no reason to inform her of possible complications.

On appeal, counsel for Ms. Aych concedes that she did not inform Dr. Pierce of her heart murmur, but contends that she would have done so had he advised her, as required by La.Rev.Stat. 40:1299.131, of the general risk of death, brain damage, quadriplegia or paraplegia associated with having her tooth extracted. She argues that, had the jury been charged that Dr. Pierce had a statutory duty to disclose all known risks associated with the extraction before he could proceed, it could only have concluded that she would have advised him she had a heart murmur, and been pre-treated with antibiotics.

In response to this argument, Dr. Pierce focuses on his alleged failure to inform Ms. Aych of the specific risks tooth extraction posed for someone with a 14heart murmur. [615]*615Noting that Ms. Aych’s concession that she did not advise him that she had a heart murmur contradicts her testimony at trial, Dr. Pierce argues that jury found her not to be credible.

Louisiana Revised Statute 40:1299.131 clearly imposes a duty on a dentist to ensure that his patients are informed of certain general risks associated with the treatment they propose to render. The evidence shows that Dr. Pierce breached that duty so that the trial court improperly excluded the requested jury instruction.

However, the mere fact that a court erred in instructing the jury does not, in and of itself, justify our conducting a trial de novo, without first measuring the gravity of the error, and considering the instructions as a whole and the circumstances of the case. Williams v. Golden, 95-2712 (La.App. 4th Cir.7/23/97), 699 So.2d 102, 106; Barnett v. New Orleans Public Service, Inc., 489 So.2d 452 (La.App. 4th Cir.1986). The manifest error standard of appellate review may not be ignored unless the jury charges were so incorrect or inadequate as to preclude its reaching a verdict based on the law and the facts. Brown v. White, 405 So.2d 555 (La. App. 4th Cir.1981).

Our review of the record convinces us that the failure of the trial court to instruct the jury on Dr. Pierce’s statutory duty to inform Ms. Aych of the general risks associated with tooth extraction, based on the circumstances of this case, did not preclude the jury from reaching a verdict based on the facts and law.

On August 7, 1990, Ms. Aych visited Dr. Pierce’s dental office for the purpose of having a tooth pulled. As a first time patient, she was asked to complete an information sheet, which included a medical history section. She checked “no” for heart condition. She also did not report a heart murmur on the line marked “Other.” Ms. Aych claimed that she asked the receptionist if she | sshould check yes for “Heart condition,” because she had a heart murmur, but was told to cheek “no” because heart condition only meant something serious like a" heart attack or heart surgery. She testified that the receptionist did advise her to tell the doctor about the murmur.

Ms. Aych testified that after completing the information sheet, she was shown to the back by someone she thought was the dental hygienist. She claimed that Dr.

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Related

Barnett v. New Orleans Public Service, Inc.
489 So. 2d 452 (Louisiana Court of Appeal, 1986)
Williams v. Golden
699 So. 2d 102 (Louisiana Court of Appeal, 1997)
Brown v. White
405 So. 2d 555 (Louisiana Court of Appeal, 1981)
Housley v. Cerise
579 So. 2d 973 (Supreme Court of Louisiana, 1991)

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Bluebook (online)
715 So. 2d 613, 1998 La. App. LEXIS 1737, 1998 WL 352807, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-medical-review-panel-of-aych-lactapp-1998.