Joan Vecchio v. Women & Infants Hospital

CourtSupreme Court of Rhode Island
DecidedMay 30, 2023
Docket21-278
StatusPublished

This text of Joan Vecchio v. Women & Infants Hospital (Joan Vecchio v. Women & Infants Hospital) is published on Counsel Stack Legal Research, covering Supreme Court of Rhode Island primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Joan Vecchio v. Women & Infants Hospital, (R.I. 2023).

Opinion

May 30, 2023 Supreme Court

No. 2021-278-M.P. (PC 17-3159)

(Dissent begins on Page 13)

Joan Vecchio :

v. :

Women & Infants Hospital. :

NOTICE: This opinion is subject to formal revision before publication in the Rhode Island Reporter. Readers are requested to notify the Opinion Analyst, Supreme Court of Rhode Island, 250 Benefit Street, Providence, Rhode Island 02903, at Telephone (401) 222-3258 or Email opinionanalyst@courts.ri.gov, of any typographical or other formal errors in order that corrections may be made before the opinion is published. Supreme Court

Present: Suttell, C.J., Goldberg, and Lynch Prata, JJ.

OPINION

Justice Lynch Prata, for the Court. The plaintiff, Joan Vecchio (Vecchio),

seeks review of a Superior Court order granting the defendant’s, Women & Infants

Hospital (W&I Hospital), motion for a protective order limiting the deposition

testimony of Vecchio’s expert witness, David Brewster, M.D. (Dr. Brewster), to

causation opinions and prohibiting Vecchio from further supplementing Dr.

Brewster’s disclosure to include other opinions. Before this Court, Vecchio

contends that the Superior Court order should be overturned, arguing that: (1) the

supplemental disclosure of Dr. Brewster was the product of trial preparation and in

compliance with the Superior Court Rules of Civil Procedure; (2) the supplemental

disclosure was not made on the eve of trial, and, thus, W&I Hospital had sufficient

opportunity to reschedule Dr. Brewster’s deposition; and (3) prohibiting Vecchio

-1- from supplementing her expert disclosures would be drastic and inequitable, and will

hinder her right to a fair trial.

The Court issued a writ of certiorari and directed the parties to

appear and show cause why the issues raised should not be summarily decided.

After considering the parties’ written and oral submissions and carefully reviewing

the record, we conclude that cause has not been shown and that this case may be

decided without further briefing or argument. For the reasons set forth herein,

we quash the order of the Superior Court.

Facts and Travel

On September 9, 2014, Vecchio underwent a robotic-assisted radical

hysterectomy, bilateral salpingectomy, and sentinel lymph node biopsy performed

at W&I Hospital following a cervical cancer diagnosis.1 Soon after this procedure,

Vecchio began complaining of left lower extremity pain and was ultimately

diagnosed with compartment syndrome and underwent two additional medical

procedures. According to Vecchio, these additional medical procedures were the

1 The material facts of this case are not in dispute. It must be noted, however, that the parties failed to provide the Court with transcripts from any of the relevant hearings, save the transcript from the hearing on W&I Hospital’s motion for a protective order, which was attached as an exhibit to Vecchio’s statement filed pursuant to Article I, Rule 12A of the Supreme Court Rules of Appellate Procedure. Additionally, Vecchio’s filings made in both this Court and the lower court are noticeably devoid of details concerning Vecchio’s medical procedures and alleged injuries. We therefore glean a majority of the facts from the parties’ Rule 12A statements and previous filings made in the lower court.

-2- direct result of W&I Hospital and its agents allegedly leaving Vecchio in a restrained

position for an extended period of time during the initial procedure.

After receiving these two additional emergency medical procedures and being

released from W&I Hospital, Vecchio filed the instant medical malpractice action

on July 6, 2017. Vecchio amended her complaint twice; once on October 24, 2017,

and again on April 26, 2018. In her second amended complaint, Vecchio asserted

claims of negligence on the part of W&I Hospital, res ipsa loquitur, and medical

malpractice on the part of W&I Hospital and its agents. More specifically, Vecchio

alleged that W&I Hospital’s treatment was “below the ‘standard of care’ that a

professional medical services entity should render to a patient.” Vecchio also

alleged that the type of injury she sustained did not ordinarily occur absent

negligence on the part of W&I Hospital. Finally, Vecchio claimed that W&I

Hospital and its agents performed the initial medical procedure in a negligent and

unprofessional manner by leaving her in a restrained position for an extended period

of time. According to Vecchio, W&I Hospital’s failure to properly perform the

initial procedure in accordance with the professional standard of care caused

complications, which required emergency medical procedures to correct.

On October 25, 2019, the trial justice entered a scheduling order requiring,

among other things, Vecchio to make her expert disclosures on or before February

-3- 1, 2020.2 Vecchio failed to meet this February 1, 2020 deadline and, as a result,

filed a motion to amend the scheduling order seeking additional time for expert

disclosures. Because of the COVID-19 pandemic, however, Vecchio’s motion was

heard approximately five months later, in July 2020. Ultimately, the trial justice

granted Vecchio’s motion and allowed her up to, and including, September 1, 2020,

to make her expert disclosures.

In accordance therewith, Vecchio provided W&I Hospital with her expert

disclosures, as well as her supplemental answer to Interrogatory No. 23, which

indicated that Vecchio intended to call two expert witnesses at trial. According to

Vecchio’s disclosure, Dr. Brewster would “testify as to the cause of compartmental

[sic] syndrome suffered by the Plaintiff as a result of prolonged surgery in the

lithotomy position based on the operative notes[,]” and Amer Karam, M.D. (Dr.

Karam), would testify “that positioning a patient in the lithotomy position without a

repositioning for an extended period of time, as was experienced by the Plaintiff, is

a deviation from the standard of care which led to the Plaintiff suffering from

compartmental [sic] syndrome.” W&I Hospital responded to Vecchio’s expert

disclosures by filing a motion for summary judgment on September 3, 2020,

2 The procedural history of this matter is somewhat unclear due to the lack of transcripts. Consequently, as with the facts of this matter, the procedural history will be gleaned largely from the lower court docket, and the parties’ Rule 12A statements and previous filings made in the lower court.

-4- contending that Vecchio’s disclosures, namely that of Dr. Karam, were insufficient

to establish negligence because the disclosures failed to provide any information

regarding the substance of the proposed experts’ opinions and were devoid of any

facts upon which the experts based their opinions.

On September 23, 2020, the parties were heard on W&I Hospital’s motion for

summary judgment. Thereafter, W&I Hospital conducted the deposition of Dr.

Karam on November 19, 2020. It was during this deposition that Dr. Karam testified

that, after reviewing the surgical positioning policy in effect at the time of Vecchio’s

surgery, he no longer believed that W&I Hospital and/or its agents deviated from the

standard of care. According to W&I Hospital, this deposition of Dr. Karam came as

a result of the trial justice providing Vecchio up to and including September 30,

2020, to remedy the deficiencies in Dr. Karam’s opinions, passing the motion for

summary judgment without prejudice, and directing W&I Hospital to depose Dr.

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Joan Vecchio v. Women & Infants Hospital, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joan-vecchio-v-women-infants-hospital-ri-2023.