Kelley v. Franklin Cty Rehab

CourtVermont Superior Court
DecidedOctober 1, 2025
Docket21-cv-323
StatusUnknown

This text of Kelley v. Franklin Cty Rehab (Kelley v. Franklin Cty Rehab) is published on Counsel Stack Legal Research, covering Vermont Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kelley v. Franklin Cty Rehab, (Vt. Ct. App. 2025).

Opinion

7ermont Superior Court Filed 06/27/25 Chittenden Unit

VERMONT SUPERIOR COURT CIVIL DIVISION Chittenden Unit Case No. 21-CV-00323 175 Main Street

Burlington VT 05401 802-863-3467 www.vermontjudiciary.org Bruce Kelley, et al v. Franklin County Rehab Center, LLC d/b/a Franklin County Rehabilitation Center and d/b/a Franklin County Rehabilitation & Adult Care Center, et al

ENTRY REGARDING MOTION Title: Motion; Motion to Exclude the Expert Opinions of Jacob R. Rachlin M.D.; to Exclude the Expert Opinions of Clifford J. Eskey M.D. (Motion: 12; 13) Filer: Kevin Lumpkin; Kevin Lumpkin Filed Date: February 28, 2025; February 28, 2025

The motion is GRANTED IN PART and DENIED IN PART.

This is Cca medical malpractice case involving damage to the Plaintiff Bruce

Kelly's spinal cord. Defendant University of Vermont Medical Center (UVMMC) has

filed the present motions in limine seeking to exclude portions of Plaintiff's experts'

opinions that Dr. Andrew Stanley breached the duty of care for a vascular surgeon

when he operated on Plaintiff Kelly for a spinal cord ischemia, when Kelly was, in

fact, suffering from a spinal subdural hematoma.

Entry Regarding Motion Page 1 of 10 21-CV-00323 Bruce Kelley, et al v. Franklin County Rehab Center, LLC d/b/a Franklin County Rehabilitation Center and d/b/a Franklin County Rehabilitation & Adult Care Center, et al Background Facts

For purposes of this motion, the facts may be summarized as follows. In

2017, Kelly became hospitalized at UVMMC due to vascular issues in his legs. He

began treatment under Dr. Stanley and underwent a complex vascular surgery called

a Thoracic Endovascular Aortic Repair. Several days after the surgery, he was

discharged to Defendant Franklin County Rehab Center (FCRC) for rehabilitation

and further care. To move Kelly into his bed, FCRC used a "Hoyer lift," a portion of

which struck Kelly in the back during the procedure. Shortly after his admission at

FCRC, Kelly reported altered sensation and motor function in his legs. The next

morning FCRC sent Kelly to Northwestern Medical Center for a different issue.

Northwestern, upon learning of the leg and sensation issues sent him back to

UVMMC.

UVMMC readmitted Kelly at 12:03 p.m. to the same surgical unit that he had

been discharged from the day before, and Dr. Stanley resumed charge over Kelly's

care. At 2:54 p.m., Dr. Stanley made an initial determination that the symptoms

Kelly was describing were most likely caused by spinal cord ischemia, a vascular

issue that is a known side effect of the surgery although Dr. Stanley's notes indicate

that it was an unusual case as most incidents occur within 8-12 hours after surgery,

rather than the 2 weeks Kelly was experiencing. At 5 p.m., UVMMC ordered an MRI.

Entry Regarding Motion Page 2 of 10 21-CV-00323 Bruce Kelley, et al v. Franklin County Rehab Center, LLC d/b/a Franklin County Rehabilitation Center and d/b/a Franklin County Rehabilitation & Adult Care Center, et al At 8:28 p.m., UVMMC conducted a neurological examination. At 8:24 p.m., the

results from the MRI came back showing a spinal subdural hematoma. UVMMC

treated it as a surgical emergency. Surgery began at 11:03 p.m. Despite the

surgery, Kelly has lost the use of his legs and become paraplegic.

After filing the present action, Plaintiff Kelly timely disclosed two expert

witnesses, Dr. Jacob Rachlin, Cca neurosurgeon practicing in Boston with the VA, and

Dr. Clifford Eskey, a neuroradiologist at Dartmouth Hitchcock in New Hampshire.

Both experts have offered opinions that UVMMC, through Dr. Stanley, breached the

standard of reasonable care by treating Plaintiff Kelly as if his complaints arose

from a side-effect of the vascular surgery, rather than the neurological issue that it

turned out to be.?

UVMMC's primary and limited objection is to the qualifications of both Dr.

Rachlin and Dr. Eskey to opine on the standard of care that a vascular surgeon

might have in treating a patient returning a day after his discharge with complaints

of altered sensation in his legs and issues with motor control. UVMMC contends

that both doctors are offering opinions outside of their area of expertise.

'Dr. Stanley and Dr. Ranney, the two treating physicians at UVMMC, were dismissed as parties to the present case in January of 2025. At that time, Plaintiff and UVMMC agreed that while the physicians' actions were still the subject of this matter, they were performed as employees and agents of UVMMC, and that UVMMC would be responsible for any liability arising from their actions and judgments in this case.

Entry Regarding Motion Page 3 of 10 21-CV-00323 Bruce Kelley, et al v. Franklin County Rehab Center, LLC d/b/a Franklin County Rehabilitation Center and d/b/a Franklin County Rehabilitation & Adult Care Center, et al Legal Analysis

Plaintiff has the burden at trial of showing that Dr. Stanley's actions violate

the standard of care, which is defined by statute to mean "the degree of knowledge

or skill possessed or the degree of care ordinarily exercised by a reasonably skillful,

careful, and prudent health care professional engaged in a similar practice under the

same or similar circumstances whether or not within the State of Vermont." 12

V.S.A. § 1908(1). Given the complexity and technical nature of a medical standard

of care, the burden created by Section 1908 can be satisfied only by expert

testimony, except for the most apparent breaches. Provost v. Fletcher Allen Health

Care, Inc., 2005 VT 115, § 12 (mem.) (citing Larson v. Candlish, 144 Vt. 499, 502

(1984)). This case is no exception to the rule. Plaintiff's theory of the case requires

him to establish that UVMMC's 11-hour delay between admission and surgery was

1) the proximate cause of his injury and 2) a breach of the standard of care. This

requires Plaintiff to show that a hospital and its employees exercising the degree of

knowledge or skill exercised by a reasonably skillful, careful, and prudent health

care professional engaged in a similar practice under the same or similar

circumstances would have acted differently. 12 V.S.A. § 1908(1) (emphasis

added). This burden can only be met through the introduction of expert testimony.

Entry Regarding Motion Page 4 of 10 21-CV-00323 Bruce Kelley, et al v. Franklin County Rehab Center, LLC d/b/a Franklin County Rehabilitation Center and d/b/a Franklin County Rehabilitation & Adult Care Center, et al Vermont applies the standard for admissibility of expert testimony set forth in

Daubert v. Merrell Dow Pharm. Inc., 509 U.S. 579, 592-93 (1993), under which the

trial courts "act as gatekeepers who screen expert testimony ensuring that it is

reliable and helpful to the issue at hand before the jury hears it." 985 Assocs., Ltd. v.

Daewoo Elecs. Am., Inc. 2008 VT 14, J 6. The analysis under Daubert and 985 Assocs., Ltd., by extension, looks to the provisions of V.R.E. 702. Id. Under Rule

702, an expert witness seeking to provide an opinion must have "knowledge, skill,

experience, training, or education" in the area on which they will offer a formal

opinion or otherwise. V.R.E. 702. As one commentator described this standard:

Rule 702 contemplates two other kinds of evidence for which the expert must be "qualified" as an expert....

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Related

Daubert v. Merrell Dow Pharmaceuticals, Inc.
509 U.S. 579 (Supreme Court, 1993)
985 Associates, Ltd. v. Daewoo Electronics America, Inc.
2008 VT 14 (Supreme Court of Vermont, 2008)
Larson v. Candlish
480 A.2d 417 (Supreme Court of Vermont, 1984)
Rooney v. Medical Center Hospital of Vermont, Inc.
649 A.2d 756 (Supreme Court of Vermont, 1994)
Lexington Insurance v. Rounds
349 F. Supp. 2d 861 (D. Vermont, 2004)
Plourde v. Gladstone
190 F. Supp. 2d 708 (D. Vermont, 2002)
State v. Pelletier
818 A.2d 292 (Supreme Court of New Hampshire, 2003)
Provost v. Fletcher Allen Health Care, Inc.
2005 VT 115 (Supreme Court of Vermont, 2005)

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Bluebook (online)
Kelley v. Franklin Cty Rehab, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kelley-v-franklin-cty-rehab-vtsuperct-2025.