Kayla Arceneaux v. Lafayette General Medical Center

CourtLouisiana Court of Appeal
DecidedJuly 26, 2017
DocketCW-0017-0516
StatusUnknown

This text of Kayla Arceneaux v. Lafayette General Medical Center (Kayla Arceneaux v. Lafayette General Medical Center) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kayla Arceneaux v. Lafayette General Medical Center, (La. Ct. App. 2017).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

17-516

KAYLA ARCENEAUX

VERSUS

LAFAYETTE GENERAL MEDICAL CENTER, ET AL.

**********

ON SUPERVISORY WRIT FROM THE FIFTEENTH JUDICIAL DISTRICT COURT PARISH OF LAFAYETTE, NO. 2016-2378 HONORABLE THOMAS R. DUPLANTIER, DISTRICT JUDGE

PHYLLIS M. KEATY JUDGE

Court composed of John D. Saunders, Phyllis M. Keaty, and Candyce G. Perret, Judges.

WRIT GRANTED; JUDGMENT REVERSED; REMANDED.

Nicholas Gachassin, III Holly McKay Descant Gachassin Law Firm Post Office Box 80369 Lafayette, Louisiana 70598-0369 (337) 235-4576 Counsel for Defendant/Applicant: Lafayette General Medical Center Patrick D. Magee Voorhies & Labbe Post Office Box 3527 Lafayette, Louisiana 70502-3527 (337) 232-9700 Counsel for Defendant: Bobby Nevils, M.D.

Harold D. Register, III Attorney at Law Post Office Box 80214 Lafayette, Louisiana 70598-0214 (337) 981-6644 Counsel for Plaintiff/Respondent: Kayla Arceneaux KEATY, Judge.

In this medical malpractice case, defendant-relator, Lafayette General

Medical Center (LGMC or the hospital), filed a motion for summary judgment

seeking to have the claims against it by plaintiff-respondent, Kayla Arceneaux,

dismissed with prejudice on the basis that she failed to present any evidence to

establish that it breached the applicable standard of care or that any alleged breach

caused her damages. At the conclusion of the hearing on LGMC’s motion, the trial

court granted plaintiff a ninety-day extension to produce an expert and disclose the

expert’s opinion to it and the hospital. A judgment memorializing the trial court’s

ruling was signed on May 15, 2017, and LGMC seeks supervisory writs from that

judgment. For the following reasons, we grant the writ, reverse the trial court’s

judgment, and remand.

STATEMENT OF THE CASE

The plaintiff was admitted into LGMC on January 13, 2014, when she was

approximately thirty to thirty-one weeks pregnant. According to the petition,

plaintiff’s obstetrician/gynecologist, Dr. Bobby Nevils, wanted hourly fetal

monitoring. Over the course of the next few days, the fetal monitor was removed;

however, there is a dispute concerning whether this was done at plaintiff’s request.

By January 15, 2014, fetal heart tones were no longer detected. The next day,

plaintiff delivered a stillborn male with hydrocephalus, commonly known as water

on the brain. Within several days of the delivery, plaintiff began to complain that

she was unable to feel her legs. Two or three times during her care, plaintiff fell to

the floor as she was being assisted out of bed by nurses and/or aides.

On December 30, 2014, plaintiff filed a request for a medical review panel

(MRP), which rendered a unanimous opinion finding that neither LGMC nor Dr. Nevils failed to meet the applicable standard of care. Plaintiff filed the instant

suit on May 3, 2016. 1 According to plaintiff’s petition, she “suffered a disc

protrusion at L2-L3” and “incurred extensive medical expenses” “[a]s a result of

the negligent care of the nurses and/or hospital personnel.” LGMC answered the

suit, joining therewith an exception of vagueness and ambiguity and a motion to

strike portions of plaintiff’s petition. As evidenced in a Consent Judgment signed

on July 25, 2016, plaintiff agreed to the entry of an order granting LGMC’s

exception and motion. On January 18, 2017, LGMC filed a motion for summary

judgment on the ground that plaintiff had no experts to establish the standard of

care or breach thereof so as to meet her burden of proof. In support of its motion,

LGMC filed the MRP opinion and reasons. 2 Due to the fact that discovery

remained outstanding at the time, plaintiff requested and the trial court signed an

Unopposed Motion to Continue resetting the hearing on LGMC’s motion from

March 6, 2017, to May 1, 2017. As to the merits of LGMC’s motion, Plaintiff

argued that LGMC’s malpractice was so obvious that a layperson could infer

negligence without expert testimony. Four exhibits were attached to plaintiff’s

opposition, consisting of affidavits executed by her and her mother, progress notes

from her stay at LGMC, and two LGMC Patient Safety Reports concerning two

falls that occurred during her hospital stay.

At the May 1, 2017 hearing, the trial court stated:

I’m not even going to recite the facts of this . . . . There’s no doubt in the world you cannot survive a medical malpractice case without an 1 Dr. Nevils was also named as a defendant. While the complained-of-judgment indicates that counsel for Dr. Nevils was present at the hearing on LGMC’s motion for summary judgment, we are unable to determine from LGMC’s writ application the status of plaintiff’s claims against him. 2 LGMC also attached to its motion copies of its certificate of enrollment in the Louisiana Patient’s Compensation Fund, plaintiff’s petition, and its answer to the petition.

2 expert. Either you get an expert or I dismiss the case. I’m not even going to talk about it. You can’t have a claimant say this happened to me, it’s negligence. That doesn’t work in medical malpractice. So I’ve got nothing else to say.

....

It’s causation that you’re having a problem with . . . . It’s not whether the baby didn’t survive. It’s causation. You have to bring the cause to the facts.

You say it was because the fetal heart monitor wasn’t attached, but nobody else said that. I don’t know that. That’s you and your client. You’re not an expert. You can’t tell me, or the trier of the fact, that. ....

The whole point is, you have to have an expert that says the bulge results from a fall, as opposed to being scoliosis, as opposed to being spondylolisthesis, as opposed to being something that’s [] hereditary. You say there was no results prior to that. So you need an expert to say that when someone falls to a floor from a three-foot point of view or whatever, that that could cause someone to have a bulging disc. That’s what the requirements of the medical malpractice are. I didn’t make those.

Rather than ruling on the motion for summary judgment, however, the trial court

gave plaintiff ninety days to retain an expert, warning that her case against LGMC

would be dismissed should she fail to do so. LGMC seeks review of the trial

court’s judgment which granted plaintiff an extension that she did not request.

LGMC asks this court to reverse the trial court judgment and render a decision

granting summary judgment in its favor.

SUPERVISORY RELIEF

“The proper procedural vehicle to contest an interlocutory judgment that

does not cause irreparable harm is an application for supervisory writs. See La.

C.C.P. arts. 2087 and 2201.” Brown v. Sanders, 06-1171, p. 2 (La.App. 1 Cir.

3/23/07), 960 So.2d 931, 933. But see La.Code Civ.P. art. 2083, comment (b),

3 which provides, in pertinent part, that “[i]rreparable injury continues to be an

important (but not exclusive) ingredient in an application for supervisory writs.”

“A court of appeal has plenary power to exercise supervisory jurisdiction

over district courts and may do so at any time, according to the discretion of the

court.” Herlitz Const. Co., Inc. v. Hotel Investors of New Iberia, Inc., 396 So.2d

878, 878 (La.1981) (per curiam). “This general policy, however, should not be

applied mechanically.” Id. Thus, when the trial court’s ruling:

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