Joan Hendley v. Glenn Evans

CourtCourt of Appeals of Georgia
DecidedNovember 21, 2012
DocketA12A1218
StatusPublished

This text of Joan Hendley v. Glenn Evans (Joan Hendley v. Glenn Evans) 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
Joan Hendley v. Glenn Evans, (Ga. Ct. App. 2012).

Opinion

SECOND DIVISION BARNES, P. J., ADAMS and MCFADDEN, 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. (Court of Appeals Rule 4 (b) and Rule 37 (b), February 21, 2008) http://www.gaappeals.us/rules/

November 21, 2012

In the Court of Appeals of Georgia A12A1218. HENDLEY et al. v. EVANS et al.

MCFADDEN, Judge.

Joan and John Hendley sued Glenn Evans, M. D. and his employer, Valdosta

Medical Clinic, P. C. (the defendants), for medical malpractice. The Hendleys

contend that Joan Hendley suffered a vessel collapse during a medical procedure

performed by Dr. Evans. They contend that Joan Hendley sustained brain damage and

other physical injuries as a result of acts and omissions of Dr. Evans and of hospital

personnel who were working under Dr. Evans’s supervision at the time of the

collapse. A jury returned a defense verdict, upon which the trial court entered

judgment. The Hendleys appeal.

The Hendleys argue that the trial court erred in failing to give any of several

jury charges they requested on the issue of Dr. Evans’s potential vicarious liability for the acts and omissions of hospital personnel. We agree that the trial court was

required to charge on this theory of recovery, and accordingly we reverse.

We find no merit, however, in the Hendleys’ arguments that the trial court erred

in failing to give other requested charges on evidentiary presumptions and

circumstantial evidence or in giving Dr. Evans’s requested charge on accepted risk.

Finally, in light of our disposition and given the impending change to Georgia’s

evidence rules, we do not address the Hendleys’ claim that the court erred in

excluding as hearsay certain witness testimony that they argued was subject to the res

geste exception.

1. Facts and proceedings below.

The trial evidence showed that on November 9, 2005, a doctor in Dr. Evans’s

practice performed a diagnostic heart catheterization procedure on Mrs. Hendley at

a hospital. During the catheterization procedure, that doctor decided that Mrs.

Hendley also should undergo an angioplasty procedure to insert stents into some of

her blood vessels.

Dr. Evans performed the angioplasty procedure. During that procedure, Mrs.

Hendley’s blood pressure dropped and one of her blood vessels collapsed. Dr. Evans

then called a “Code Blue.” Hospital personnel in the operating room performed CPR

2 on Mrs. Hendley and, after multiple attempts, intubated her. During the Code,

however, Mrs. Hendley’s oxygen saturation dropped to a dangerous level. The

Hendleys presented evidence that she sustained some brain damage from lack of

oxygen following the vascular collapse.

Mrs. Hendley remained intubated for several weeks after the Code due to

complications, and after several unsuccessful attempts at extubation she underwent

a tracheotomy. The doctor who performed the tracheotomy found damaged tissue and

scarring in her esophagus. The Hendleys presented evidence that this scarring was a

complication of the multiple intubation attempts and prolonged intubation. After

continued complications and additional surgeries, Mrs. Hendley’s voice box was

removed and she is now permanently dependent on a tracheostomy.

2. Jury charges.

The Hendleys argue that the trial court erred in denying their requests for jury

charges on the following issues: the borrowed servant doctrine, respondeat superior,

agency, imputed negligence, evidentiary presumptions arising from a party’s failure

to produce evidence or witness testimony, and circumstantial evidence. They also

argue that the trial court erred in giving the defendants’ requested charge on accepted

risk.

3 “A charge on a given subject is justified if there is even slight evidence from

which a jury could infer a conclusion regarding that subject.” (Citations and

punctuation omitted.) Gates v. Navy, 274 Ga. App. 180, 183 (4) (617 SE2d 163)

(2005). A trial court may deny a specific request to charge if any portion of the

request is inapt or incorrect, because a request to charge must be “correct, legal, apt,

even perfect, and precisely adjusted to some principle involved in the case.” (Citation

omitted.) Lifestyle Family, L. P. v. Lawyers Title Ins. Corp., 256 Ga. App. 305, 311

(3) (568 SE2d 171) (2002). Nevertheless, “[a] trial court must instruct a jury on the

law as to every controlling, material, substantial and vital issue in the case. The

failure to charge on a properly asserted and legally cognizable theory of recovery,

whether requested or not, or attention be called to it or not, is harmful as a matter of

law.” (Citations and punctuation omitted.) Duffield v. Chui, 314 Ga. App. 214, 214-

215 (723 SE2d 506) (2012). Accord Tempo Mgmt. v. Lewis, 210 Ga. App. 390, 391

(1) (436 SE2d 98) (1993).

(a) The trial court erred in failing to charge the jury on Dr. Evans’s potential

vicarious liability for the negligence of hospital personnel.

Concerning the issue of Dr. Evans’s vicarious liability, the Hendleys sought

that the jury be charged on the borrowed servant doctrine or, alternatively, be given

4 the pattern charges on respondeat superior, agency and imputed negligence. The trial

court, however, declined to give any of these requested charges, and its final charge

did not instruct the jury on the issue of Dr. Evans’s possible vicarious liability.

As detailed below, the trial court did not err in declining to give the specific

charge that the Hendleys requested on the borrowed servant doctrine, because it was

not a fully accurate statement of the law. The Hendleys, however, presented some

evidence from which a jury could find Dr. Evans vicariously liable for the negligent

acts and omissions of hospital personnel, and the trial court was required to instruct

the jury on this theory of the Hendleys’ case. The court’s failure to give any

instruction on vicarious liability was reversible error.

(i) A doctor may be found liable under the theory of respondeat superior for the

negligent acts of his employees. See Packer v. Gill, 193 Ga. App. 388, 390 (4) (388

SE2d 338) (1989). “[T]he traditional definition of ‘employee’ . . . has for at least a

century contained within its purview borrowed servants.” Summerlin v. Ga. Pines

Community Svc. Bd., 286 Ga. 593, 595 (2) (690 SE2d 401) (2010). “Ordinarily, when

one lends his servant to another for a particular employment, the servant will be dealt

with as a servant of the person to whom he is lent, although he remains the general

servant of the person who lent him.” (Citations omitted.) Merry Bros. Brick &c. v.

5 Jackson, 120 Ga. App. 716, 719 (171 SE2d 924) (1969); see Summerlin, 286 Ga. at

594 (2) (“borrowed servants are employees of the borrowing employer”) (citations

omitted).

Accordingly, the borrowed servant doctrine “is applied in the context of the tort

doctrine of respondeat superior.” Summerlin, 286 Ga. at 596 (2); see Staffing

Resources v. Nash, 218 Ga. App. 525 (1) (462 SE2d 401) (1995). It is a means of

transferring the vicarious liability for an employee’s negligence from a lending

employer to a borrowing employer. See Hoffman v. Wells, 260 Ga. 588, 590 (2) (397

SE2d 696) (1990) (discussing borrowed servant doctrine as effecting a transfer of

vicarious liability); Ross v.

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