Jewish Hospital & St. Mary's Healthcare, Inc, D/B/A Jewish Hospital Medical Center South v. Darrell House Co-Guardian of Kaylen Alexander, a Minor

CourtKentucky Supreme Court
DecidedDecember 13, 2018
Docket2017-SC-0440
StatusUnpublished

This text of Jewish Hospital & St. Mary's Healthcare, Inc, D/B/A Jewish Hospital Medical Center South v. Darrell House Co-Guardian of Kaylen Alexander, a Minor (Jewish Hospital & St. Mary's Healthcare, Inc, D/B/A Jewish Hospital Medical Center South v. Darrell House Co-Guardian of Kaylen Alexander, a Minor) is published on Counsel Stack Legal Research, covering Kentucky Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Jewish Hospital & St. Mary's Healthcare, Inc, D/B/A Jewish Hospital Medical Center South v. Darrell House Co-Guardian of Kaylen Alexander, a Minor, (Ky. 2018).

Opinion

RENDERED: DECEMBER 13, 2018 TO BE PUBLISHED

2017-SC-000440-DG

JEWISH HOSPITAL & ST. MARY’S APPELLANT HEALTHCARE, INC. D/B/A JEWISH HOSPITAL MEDICAL CENTER SOUTH

ON REVIEW FROM COURT OF APPEALS V. CASE NOS. 2015-CA-001205 AND 2015-CA-001278 BULLITT CIRCUIT COURT NO. 12-CI-01132

BARBARA HOUSE, ADMINISTRATRIX OF APPELLEES THE ESTATE OF LAURA B. ALEXANDER, DECEASED; BARBARA HOUSE, CO- GUARDIAN OF KAYLEN ALEXANDER, A MINOR; AND DARRELL HOUSE, CO- GUARDIAN OF KAYLEN ALEXANDER, A MINOR

OPINION OF THE COURT BY JUSTICE KELLER

REVERSING AND REINSTATING

Laura Alexander was a patient at Jewish Hospital Medical Center South

(“Jewish Hospital”). She was treated and released on November 28, 2011.

Tragically, later that evening, Laura was taken by ambulance to Jewish

Hospital in downtown Louisville. She died several hours later from cardiac

arrest secondary to a staph aureus infection in her blood. Barbara House,

Laura’s mother and administratrix of her estate, brought suit in Bullitt Circuit

Court, alleging medical malpractice against Dr. Charles Sherrard, Jr., Jewish

Hospital, and Dr. Sherrard’s professional group. Dr. Sherrard settled the claims against him but the case against Jewish Hospital proceeded to trial,

after which a jury found in favor of Jewish Hospital. The Court of Appeals

reversed and remanded for a new trial. This Court granted discretionary

review. For the following reasons, we now reverse and reinstate the judgment

of the Bullitt Circuit Court.

I. BACKGROUND

Laura, then thirty-three years old, came into Jewish Hospital’s

Emergency Room (“ER”) early on the morning of November 28, 2011. She

complained of dark urine, feeling dehydrated, muscular pain, and weakness in

her arms and legs. Although her blood pressure was in the normal range, her

heartrate was elevated at 148 beats per minute (bpm). Dr. Sherrard evaluated

Laura at approximately 6:15 a.m.; he obtained a medical history, ordered lab

tests, and ordered two liters of intravenous fluids to be administered.

Early during Laura’s stay, the nursing shift changed, and Nurse Charity

Johnston began assisting in Laura’s treatment. Johnston administered the

first liter of fluids at 6:30 a.m.; at 8:08 a.m., Dr. Sherrard re-evaluated Laura

and noted that her heartrate had decreased to between 114 and 118 bpm.

During this re-evaluation, Laura informed Dr. Sherrard that she had exercised

strenuously a few days earlier. Due to this new information, Dr. Sherrard

suspected that Laura’s symptoms were caused by rhabdomyolysis, muscle

fibers breaking down after physical damage. Laura’s potassium was decreased

in her lab results so Dr. Sherrard also diagnosed Laura with hypokalemia, a

2 potassium deficiency, as well as acute dehydration, exercised-induced myositis

(inflammation of muscle tissue), and myofascial (muscular irritation) pain.

At 8:15 a.m., Dr. Sherrard entered an order discharging Laura,

conditioned upon her receiving a second liter of fluids. Johnston administered

the second liter at 8:18 a.m. At that time, Laura’s heartrate was 124 bpm. At

9:47 a.m., Johnston discharged Laura. At that time her heartrate was 132

bpm. Although her heartrate was lower than when she first presented in the

ER, it was higher than when Dr. Sherrard had last evaluated Laura. Johnston

did not notify Dr. Sherrard of this change but, instead, continued with the

discharge instruction. Johnston stated that she felt, in her nursing judgment,

that Laura’s heartrate at discharge was consistent with what it had been at the

time Dr. Sherrard had ordered the conditional discharge.

Laura’s discharge from Jewish Hospital, while still tachycardic, was the

focal point of the alleged malpractice of both Dr. Sherrard and Nurse Johnston.

During his deposition testimony, Dr. Sherrard explained that there were

several factors he felt contributed to Laura’s increased heartrate: she had just

finished taking Flexeril (prescribed for muscular pain) which can cause

tachycardia; tachycardia can occur with dehydration and may not completely

resolve with fluids; and Laura’s heartrate at a recent visit to the ER was also

above 100, so her baseline may be higher than normal.

Laura went home with her mother and spent most of the day in bed. At

about 7:00 p.m. that same evening, Laura experienced sudden shortness of

breath and paralysis in her arms and legs. She was taken by ambulance to

3 Jewish Hospital’s downtown Louisville facility. After a thorough examination

and aggressive care, doctors determined that Laura was in septic shock. When

Laura visited the emergency room earlier that day, she had not presented with

fever, chills, or any of the normal signs of infection, per Dr. Sherrard. Upon

admission that evening, the doctors and nurses at the downtown facility

administered antibiotics upon determining she was in septic shock. Sadly, the

professionals were unable to save Laura. She passed away shortly after

midnight from cardiac arrest, secondary to a staph aureus infection in her

blood. It was later determined that Laura had been treated several weeks prior

for a boil;1 it had been surgically lanced and was the probable cause of the

sepsis that led to Laura’s death.

Dr. Sherrard settled Laura’s estate’s claims against him. The claims

against Jewish Hospital proceeded to trial. Dr. Sherrard was not present at

trial; his video deposition was played for the jury. He was still included as a

party to the proceedings for apportionment purposes under Kentucky Revised

Statute (“KRS”) 411.182.2 At the close of plaintiffs case, Jewish Hospital’s

counsel moved for directed verdict, claiming that the plaintiffs had failed to

prove causation. The trial court denied the motion. Jewish Hospital then

1 This fact was unknown to Dr. Sherrard or Jewish Hospital personnel when Laura came into the ER that morning. 2 “In all tort actions ... involving fault of more than one (1) party ... including third-party defendants and persons who have been released ... the court ... shall instruct the jury to answer interrogatories ... indicating: (a) The amount of damages each claimant would be entitled to recover if contributory fault is disregarded; and (b) The percentage of the total fault of all the parties to each claim that is allocated to each claimant, defendant, third-party defendant, and person who has been released from liability ...” KRS 411.182( 1).

4 moved for directed verdict on standard of care as to Dr. Sherrard; counsel

argued that it was undisputed by the parties that Dr. Sherrard’s conduct fell

below the standard of care. Laura’s estate’s counsel argued that, from Dr.

Sherrard’s video testimony, he testified that his conduct was appropriate.

Because Dr. Sherrard was an expert witness, this testimony was sufficient to

create an issue of fact for the jury. The judge granted Jewish Hospital’s

motion, stating that each of the expert witnesses presented by Laura’s estate

had testified that Dr. Sherrard’s conduct was below the standard of care. The

case was presented to the jury with an instruction that Dr. Sherrard had fallen

below the standard of care. The jury returned a verdict for Jewish Hospital.

The Estate appealed. The Court of Appeals determined that, not only

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Jewish Hospital & St. Mary's Healthcare, Inc, D/B/A Jewish Hospital Medical Center South v. Darrell House Co-Guardian of Kaylen Alexander, a Minor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jewish-hospital-st-marys-healthcare-inc-dba-jewish-hospital-medical-ky-2018.