Judy F. Smith v. Kurt F. Jaenicke, M.D.

CourtCourt of Appeals of Kentucky
DecidedAugust 9, 2024
Docket2023-CA-0935
StatusUnpublished

This text of Judy F. Smith v. Kurt F. Jaenicke, M.D. (Judy F. Smith v. Kurt F. Jaenicke, M.D.) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Judy F. Smith v. Kurt F. Jaenicke, M.D., (Ky. Ct. App. 2024).

Opinion

RENDERED: AUGUST 9, 2024; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2023-CA-0935-MR

JUDY F. SMITH APPELLANT

APPEAL FROM GREENUP CIRCUIT COURT v. HONORABLE BRIAN CHRISTOPHER MCCLOUD, JUDGE ACTION NO. 20-CI-00443

KURT F. JAENICKE, M.D. APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: COMBS, A. JONES, AND KAREM, JUDGES.

KAREM, JUDGE: Judy F. Smith (“Smith”) appeals the Greenup Circuit Court’s

order granting summary judgment in favor of Dr. Kurt F. Jaenicke (“Dr. Jaenicke”)

in a medical malpractice case. The circuit court determined that Smith had failed

to present expert testimony supporting her allegation that she suffered an injury

caused by negligence on the part of Dr. Jaenicke. Finding no error, we affirm. FACTUAL AND PROCEDURAL BACKGROUND

On December 3, 2019, Dr. Jaenicke performed surgery on Smith to

repair a pelvic organ prolapse. During the procedure, Dr. Jaenicke discovered one

or more “large[,] prolapsed hemorrhoid[s]” and performed a hemorrhoidectomy for

their removal.

Thereafter, on November 10, 2020, Smith filed a complaint in the

circuit court. In her complaint, Smith alleged that Dr. Jaenicke owed her a duty to

obtain her informed consent before performing the hemorrhoidectomy.1 She

further alleged that “as the direct and proximate result of the unauthorized and

negligently performed hemorrhoidectomy and/or anal surgery, [Smith] sustained

anal stenosis, scarring and was otherwise seriously and permanently injured and

damaged.” Finally, Smith further contended that she had incurred and would incur

medical expenses, lost wages, and earning capacity in the future, and had suffered

extreme pain, suffering, and mental anguish.

The litigation in this matter proceeded, and on May 15, 2023 – after

the period for naming expert witnesses had passed – Dr. Jaenicke filed a motion for

summary judgment on the basis that none of Smith’s identified experts would offer

1 In its order, the circuit court did not discuss or rule on informed consent as it related to any breach of the standard of care in this case. Further, Smith specifically indicates in her brief that the appeal “centers solely on the proof of causation[,] i.e., whether medical expert testimony is needed to establish that the hemorrhoidectomy caused injury to [Smith].”

-2- testimony supporting her claims that the hemorrhoidectomy caused her alleged

injuries at issue in the case.

Smith opposed the motion for summary judgment, contending that Dr.

Jaenicke had testified at his deposition that hemorrhoidectomies are painful and

hurt. Smith further argued that another of her treating physicians, Dr. Jon

Hourigan, had testified and documented that he performed a surgical evaluation

and that Smith had sustained a condition similar to anal stenosis with anal scarring

secondary to the hemorrhoidectomy. As a result, Smith contended that the circuit

court should not grant summary judgment.

On July 14, 2023, the circuit court granted summary judgment to Dr.

Jaenicke, finding that Smith failed to present expert testimony supporting her

allegations that she suffered any injury caused by Dr. Jaenicke’s negligence. Thus,

no genuine issue of material fact existed regarding two essential elements of

Smith’s negligence claim; causation and damages. This appeal followed.

We will discuss further facts as they become relevant.

ANALYSIS

1. Standard of Review

Kentucky Rule of Civil Procedure (“CR”) 56.03 authorizes a motion

for summary judgment “if the pleadings, depositions, answers to interrogatories,

stipulations, and admissions on file, together with the affidavits, if any, show that

-3- there is no genuine issue as to any material fact and that the moving party is

entitled to a judgment as a matter of law.” A court must view the record “in a light

most favorable to the party opposing the motion for summary judgment and all

doubts are to be resolved in his favor.” Steelvest, Inc. v. Scansteel Service Center,

Inc., 807 S.W.2d 476, 480 (Ky. 1991) (citations omitted). “If the litigants are

given an opportunity to present evidence which reveals the existence of disputed

material facts and upon the trial court’s determination that there are no such

disputed facts, summary judgment is appropriate.” Ross v. Powell, 206 S.W.3d

327, 330 (Ky. 2006). Further, “[w]hether summary judgment is appropriate is a

legal question involving no factual findings, so the trial court’s grant of summary

judgment is reviewed de novo.” McKinley v. Circle K, 435 S.W.3d 77, 79 (Ky.

App. 2014) (citation omitted).

2. Discussion

On appeal, Smith first argues that she did not need expert testimony to

prove the hemorrhoidectomy caused her injuries. Specifically, she claims it is

within the “common knowledge and experience of laymen . . . to recognize and

infer that Dr. Jaenicke caused bodily harm by cauterizing Judy Smith’s flesh and

making surgical cuts to her body[.]”

As a starting point for our analysis of Smith’s claims, “[i]t is

elementary for all tort cases that the plaintiff must establish a duty, breach thereof,

-4- causation, and injury.” Saint Elizabeth Medical Center, Inc. v. Arnsperger, 686

S.W.3d 132, 138 (Ky. 2024). Moreover, as discussed by a panel of this Court, “[i]t

is well established that in a medical malpractice case, the burden of proof is upon

the plaintiff to establish the negligence of a physician by medical or expert

testimony.” Nalley v. Banis, 240 S.W.3d 658, 660-61 (Ky. App. 2007) (citation

omitted). Indeed, expert testimony is “essential” in establishing a defendant

deviated from the standard of care and caused some injury to the plaintiff.

Blankenship v. Collier, 302 S.W.3d 665, 671 (Ky. 2010).

In some situations, Kentucky courts have recognized an exception to

the preceding requirement and have permitted the inference of negligence even in

the absence of expert testimony. Arnsperger, 686 S.W.3d at 138. In Arnsperger,

the Kentucky Supreme Court noted:

That a medical malpractice case may, in certain circumstances, proceed to trial without expert medical testimony when duty, breach, causation, and injury are readily apparent within the common knowledge of a jury has been frequently described as the “layman’s exception” in this case, but that term is a bit of a misnomer. The “layman’s exception” is in fact nothing other than the application of res ipsa loquitur – the thing speaks for itself.

Id. (citations omitted).

In this case, Dr. Jaenicke argues that Smith did not preserve her res

ipsa loquitur argument on appeal because she never raised it in a timely manner

-5- before the circuit court. Moreover, “[i]t is axiomatic that a party may not raise an

issue for the first time on appeal.” Sunrise Children’s Services, Inc. v. Kentucky

Unemployment Insurance Commission, 515 S.W.3d 186, 192 (Ky. App. 2016)

(citations omitted).

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

Related

Ross v. Powell
206 S.W.3d 327 (Kentucky Supreme Court, 2006)
Steelvest, Inc. v. Scansteel Service Center, Inc.
807 S.W.2d 476 (Kentucky Supreme Court, 1991)
Nalley v. Banis
240 S.W.3d 658 (Court of Appeals of Kentucky, 2007)
Hutchings v. Louisville Trust Company
276 S.W.2d 461 (Court of Appeals of Kentucky (pre-1976), 1954)
Blankenship v. Collier
302 S.W.3d 665 (Kentucky Supreme Court, 2010)
McKinley v. Circle K
435 S.W.3d 77 (Court of Appeals of Kentucky, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
Judy F. Smith v. Kurt F. Jaenicke, M.D., Counsel Stack Legal Research, https://law.counselstack.com/opinion/judy-f-smith-v-kurt-f-jaenicke-md-kyctapp-2024.