Johanna Woodard v. University of Mich Medical Ctr

CourtMichigan Supreme Court
DecidedJuly 12, 2005
Docket124995
StatusPublished

This text of Johanna Woodard v. University of Mich Medical Ctr (Johanna Woodard v. University of Mich Medical Ctr) is published on Counsel Stack Legal Research, covering Michigan Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Johanna Woodard v. University of Mich Medical Ctr, (Mich. 2005).

Opinion

Michigan Supreme Court Lansing, Michigan Chief Justice: Justices:

Opinion Clifford W. Taylor Michael F. Cavanagh Elizabeth A. Weaver Marilyn Kelly Maura D. Corrigan Robert P. Young, Jr. Stephen J. Markman

FILED July 12, 2005

JOHANNA WOODARD, Individually and as Next Friend of AUSTIN D. WOODARD, a Minor, and STEVEN WOODARD

Plaintiffs-Appellees,

and Cross-Appellants

v o. 124994 N

JOSEPH R. CUSTER, M.D.,

Defendant-Appellant,

and Cross-Appellee

and

MICHAEL K. LIPSCOMB, M.D., MICHELLE M. NYPAVER, M.D., and MONA M. RISKALLA, M.D.,

Defendants. ______________________________________

JOHANNA WOODARD, Individually and as Next Friend of AUSTIN D. WOODARD, a Minor, and STEVEN WOODARD,

Plaintiffs-Appellees

and Cross-Appellants,

v No. 124995

UNIVERSITY OF MICHIGAN MEDICAL CENTER,

Defendant-Appellant

and Cross-Appellee.

______________________________________

BEFORE THE ENTIRE BENCH

MARKMAN, J.

The question presented to this Court is whether expert

testimony is necessary in the circumstances of this case.

We conclude that it is.

I. FACTS AND PROCEDURAL HISTORY

Plaintiffs’ fifteen-day-old son was admitted to the

Pediatric Intensive Care Unit (PICU) at the University of

Michigan Hospital, where he was treated for a respiratory

problem. During his stay in the PICU, he was under the

care of Dr. Joseph R. Custer, the Director of Pediatric

Critical Care Medicine. When the infant was moved to the

general hospital ward, physicians in that ward discovered

that both of the infant’s legs were fractured. Plaintiffs

sued Dr. Custer and the hospital, alleging that the

fractures were the result of negligent medical procedures,

namely, the improper placement of an arterial line in the

femoral vein of the infant’s right leg and the improper

placement of a venous catheter in the infant’s left leg.

Defendant physician is board-certified in pediatrics

and has certificates of special qualifications in pediatric

critical care medicine and neonatal-perinatal medicine.

Plaintiffs’ proposed expert witness, who signed plaintiffs’

affidavit of merit, is board-certified in pediatrics, but

does not have any certificates of special qualifications.

Before discovery, the trial court denied defendants’

motion for summary disposition, concluding that plaintiffs’

attorney had a “reasonable belief” under MCL 600.2912d(1)

that plaintiffs’ proposed expert witness was qualified

under MCL 600.2169 to testify against the defendant

physician, and, thus, that plaintiffs’ affidavit of merit

was sufficient. After discovery, the trial court granted

defendants’ motion to strike plaintiffs’ expert witness on

the basis that he was not actually qualified under MCL

600.2169 to testify against the defendant physician. The

trial court dismissed plaintiffs’ claim with prejudice,

concluding that plaintiffs could not reach a jury without

expert testimony.

The Court of Appeals affirmed the trial court’s ruling

that plaintiffs’ proposed expert witness was not qualified

physician (Judge Borrello dissented on this issue), but

reversed the trial court’s dismissal on the basis that

expert testimony was unnecessary under the doctrine of res

ipsa loquitur, i.e., an inference of negligence may be

drawn from the fact that the infant was admitted to the

PICU with healthy legs and discharged from the PICU with

fractured legs (Judge Talbot dissented on this issue). 3 Unpublished opinion per curiam, issued October 21, 2003

(Docket Nos. 239868-239869). The case was remanded for

trial.

Defendants sought leave to appeal the Court of Appeals

decision that res ipsa loquitur applies and that expert

testimony was not necessary. Plaintiffs sought leave to

cross-appeal the Court of Appeals decision that their

proposed expert witness was not qualified under MCL

600.2169 to testify against the defendant physician. We

heard oral argument on whether to grant the applications or

take other peremptory action permitted by MCR 7.302(G)(1).

471 Mich 890. We have granted plaintiffs’ application for

leave to appeal as cross-appellants.1 In this opinion, we

address only defendants’ application for leave to appeal.

1 That order states:

On December 9, 2004, the Court heard oral argument on defendants’ application for leave to appeal the October 21, 2003, judgment of the Court of Appeals and plaintiffs’ cross- application for leave to appeal. Plaintiffs’ cross-application for leave to appeal is again considered and it is GRANTED. The parties are directed to include among the issues to be briefed: (1) what are the appropriate definitions of the terms “specialty” and “board certified” as used in MCL 600.2169(1)(a); (2) whether either “specialty” or “board certified” includes subspecialties or certificates of special qualifications; (3) whether MCL 600.2169(1)(b) requires an expert witness to practice or teach the same subspecialty as the defendant; (4) whether MCL 600.2169 requires an expert witness (continued…) 4 II. STANDARD OF REVIEW

This Court reviews de novo decisions on summary

disposition motions. Grossman v Brown, 470 Mich 593, 598;

685 NW2d 198 (2004).

III. ANALYSIS

Plaintiffs argue that expert testimony is unnecessary

in this case because of the doctrine of res ipsa loquitur.

In a medical malpractice case, the plaintiff must

establish:

(1) the applicable standard of care, (2) breach of that standard of care by the defendant, (3) injury, and (4) proximate causation between the alleged breach and the injury. [Locke v Pachtman, 446 Mich 216, 222; 521 NW2d 786 (1994).]

(…continued) to match all specialties, subspecialties, and certificates of special qualifications that a defendant may possess, or whether the expert witness need only match those that are relevant to the alleged act of malpractice. See Tate v Detroit Receiving Hosp, 249 Mich App 212 (2002); and (5) what are the relevant specialties, subspecialties, and certificates of special qualifications in this case.

The American Osteopathic Association’s Bureau of Osteopathic Specialists, the Accreditation Council for Graduate Medical Education, and the Council of Medical Specialty Societies are invited to file briefs amicus curiae. Other persons or groups interested in the determination of the questions presented in this case may move the Court for permission to file briefs amicus curiae. [473 Mich ___ (2005).]

See MCL 600.2912a. Generally, expert testimony is required

in medical malpractice cases. Locke, supra at 230.

This Court has long recognized the importance of expert testimony in establishing a medical malpractice claim, and the need to educate the jury and the court regarding matters not within their common purview. . . . While we have recognized exceptions to this requirement, the benefit of expert testimony, particularly in demonstrating the applicable standard of care, cannot be overstated. [Id. at 223-224.]

However, if a medical malpractice case satisfies the

requirements of the doctrine of res ipsa loquitur, then

such case may proceed to the jury without expert testimony.

Id. at 230. Res ipsa loquitur is a Latin term meaning,

“[t]he thing speaks for itself.” Black’s Law Dictionary

(6th ed).2

[R]es ipsa loquitur . . . entitles a plaintiff to a permissible inference of negligence from circumstantial evidence.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Grossman v. Brown
685 N.W.2d 198 (Michigan Supreme Court, 2004)
Halloran v. Bhan
683 N.W.2d 129 (Michigan Supreme Court, 2004)
Tate v. Detroit Receiving Hospital
642 N.W.2d 346 (Michigan Court of Appeals, 2002)
Wood v. Detroit Automobile Inter-Insurance Exchange
321 N.W.2d 653 (Michigan Supreme Court, 1982)
Jones v. Porretta
405 N.W.2d 863 (Michigan Supreme Court, 1987)
Klabunde v. Stanley
181 N.W.2d 918 (Michigan Supreme Court, 1970)
Locke v. Pachtman
521 N.W.2d 786 (Michigan Supreme Court, 1994)
Tisbury v. Armstrong
486 N.W.2d 51 (Michigan Court of Appeals, 1992)
Dean v. Tucker
451 N.W.2d 571 (Michigan Court of Appeals, 1990)

Cite This Page — Counsel Stack

Bluebook (online)
Johanna Woodard v. University of Mich Medical Ctr, Counsel Stack Legal Research, https://law.counselstack.com/opinion/johanna-woodard-v-university-of-mich-medical-ctr-mich-2005.