Kevin Anderson v. Charles Hamon, M.d.

CourtCourt of Appeals of Washington
DecidedJune 24, 2014
Docket44388-1
StatusUnpublished

This text of Kevin Anderson v. Charles Hamon, M.d. (Kevin Anderson v. Charles Hamon, M.d.) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kevin Anderson v. Charles Hamon, M.d., (Wash. Ct. App. 2014).

Opinion

FILED COURT OF A2 EALS DIVISION II 20114JUN24 AM 9 : U5

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTO

DIVISION II

KEVIN ANDERSON, No. 44388 -1 - II

Appellant, .

v.

CHARLES HAMON, M.D., UNPUBLISHED OPINION

Respondent.

LEE, J. — Kevin Anderson appeals the jury' s verdict finding Dr. Charles Hamon was not

negligent in Anderson' s care. Anderson argues that the trial court erred in admitting evidence of

his past drug use for the purposes of proving contributory negligence. We hold that the trial

court did not abuse its discretion by admitting the evidence under ER 401 and ER 403. We

affirm.

FACTS

I. BACKGROUND

Anderson began dating Jennifer Ray in September 2005, while they both lived in Hawaii.

In February 2006, Anderson moved in with Ray. Shortly after, Anderson began complaining

about being sick. On March 21, 2006, Anderson went to urgent care with a headache and

congestion. The urgent care center diagnosed Anderson with a sinus infection and prescribed

antibiotics. On March 22, Anderson began suffering from a severe headache, nausea, vomiting, No. 44388- 1- II

and photophobia. Anderson went to the emergency room. The emergency room performed a CT

scan, determined that he had a severe sinus infection, and sent him home to continue his

antibiotics.

Over the next several weeks, Anderson' s congestion improved, but his headache never

fully resolved. On May 4„ Anderson and Ray flew from Hawaii to Arizona to visit friends.

During the trip to Arizona, Anderson' s condition declined. He was tired and had a severe

headache, photophobia, anorexia ( loss of appetite), nausea, and vomiting. After a few days in

Arizona, Ray and Anderson flew to Seattle to visit Ray' s family on Bainbridge Island.

Anderson' s condition continued to worsen. During the first two days on Bainbridge Island,

Anderson stayed in bed the entire time, did not eat, and continued to experience a severe

headache and photophobia.

On the morning of May 11, Ray convinced Anderson to see a doctor. Ray drove

Anderson to see Dr. Hamon. Hamon performed a physical examination, took a medical history,

and performed a neurological exam. Anderson presented with a severe headache, photophobia,

malaise, anorexia, nausea, fever, and chills. Hamon diagnosed Anderson with a chronic sinus

infection and gave him another course of antibiotics, a decongestant, and pain medication. Ray

brought Anderson home, and he returned to bed. The next morning, Ray spoke with Anderson at

approximately 9: 30 before leaving the house to spend the day with her mother and sister. Ray

returned home at 6: 30 PM and checked on Anderson. Ray heard Anderson snoring and decided

to let him stay asleep. At 7: 30 PM Ray attempted to wake Anderson, but he did not wake up; Ray

thought he was " knocked out" from the pain medication: At approximately 8 PM, Ray attempted

2 No. 44388- 1- 11

to wake Anderson, but he was unresponsive. Ray' s sister called 911, and the responding medical

personnel airlifted Anderson to Harborview Medical Center.

At Harborview, Anderson was diagnosed with a brain abscess. The CT scan revealed a 7

cm abscess ( roughly the size and volume of a baseball). Anderson had an initial craniotomy to

drain the abscess, a sinus surgery, and a subsequent craniotomy. Eventually, Anderson regained

consciousness and began physical therapy. Anderson was discharged from Harborview on July

4, 2006. Anderson has permanent injuries resulting from his brain surgeries, including loss of

use of his right hand, blindness, and cognitive impairments.

II. PROCEDURE

On January 13, 2010, Anderson filed a medical malpractice claim against Hamon,

alleging that Hamon breached the standard of care by failing to refer Anderson to a specialist or

an emergency room for further treatment. Hamon denied the allegation and pled contributory

negligence as an affirmative defense. Prior to trial, Anderson filed a motion in limine to exclude

any evidence related to Anderson' s history of drug use. Hamon argued that Anderson' s drug

use, particularly cocaine and methamphetamine, were relevant to a defense of contributory

negligence.' The trial court allowed Hamon to introduce evidence of Anderson' s cocaine and

methamphetamine use as it relates to the cause of Anderson' s brain abscess. During the trial,

Anderson continued to raise his objection to the admissibility of any evidence of his drug use.

At trial, Ray testified that Anderson told her he had used drugs including cocaine, but that

Anderson did not use drugs while they were together. Dr. Michael Kovar, one of Hamon' s

1 In an action based on fault seeking to recover damages for injury or death to a person, any contributory fault chargeable to the claimant diminishes proportionately the amount awarded as compensatory damages for an injury attributable to the claimant's contributory fault, but does not bar recovery. RCW 4. 22. 005.

3 No. 44388 -1 - II

experts, testified that Anderson' s charts from Harborview noted cocaine use and that use of

cocaine and methamphetamine can contribute to the development of a sinus infection and brain

abscess.

Anderson presented expert testimony from several doctors who testified that Hamon

breached the standard of care by failing to refer Anderson to a specialist, to the emergency room,

or for a CT scan. Hamon, on the other hand, presented expert testimony of several doctors who 2 testified that Hamon did not breach the standard of care.

The trial court specifically instructed the jury as to Hamon' s affirmative defense of

contributory negligence:

In addition, [ Hamon] claims as an affirmative defense that the plaintiff was contributorily negligent in one or more of the following respects:

By drugs that ultimately caused the sinusitis that escalated into a large brain abscess over the course of several months, causing substantial injuries.

Clerk' s Papers ( CP) at 619. The jury was given a special verdict form that asked: " Was

defendant Charles Hamon, M.D. negligent in his care of plaintiff Kevin Anderson ?" CP at 636.

The jury answered "[ N] o." CP at 636. The jury did not reach the additional questions regarding

proximate cause, Anderson' s damages, and Anderson' s contributory negligence. Anderson

appeals.

ANALYSIS

Anderson argues that the trial court erred by admitting the evidence of his past drug use

because it was irrelevant under ER 401 and unfairly prejudicial under ER 403. The evidence of

2 It appears that Anderson and Hamon each called four doctors but the record before us on appeal does not include all of the trial testimony from each doctor.

4 No. 44388- 1- 11

Anderson' s drug use was relevant to support Hamon' s theory of contributory negligence;

therefore, the evidence was properly admitted under ER 401. In addition, the probative value of

the evidence was not substantially outweighed by any prejudice resulting from the admission of

the evidence under ER 403.

We review a trial court' s evidentiary rulings for an abuse of discretion. Mut. of

Enumclaw Ins. Co. v. Gregg Roofing, Inc., 178 Wn. App. 702, 728, 315 P. 3d 1143 ( 2013),

review denied, 180 Wn.2d 1011 ( 2014). " Therefore, we will overturn the trial court' s ruling on

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