Kevin Rittger, M.D. v. Lou Virgina Danos

CourtCourt of Appeals of Texas
DecidedJune 18, 2009
Docket01-08-00588-CV
StatusPublished

This text of Kevin Rittger, M.D. v. Lou Virgina Danos (Kevin Rittger, M.D. v. Lou Virgina Danos) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kevin Rittger, M.D. v. Lou Virgina Danos, (Tex. Ct. App. 2009).

Opinion

Opinion issued June 18, 2009







In The

Court of Appeals

For The

First District of Texas

____________


NO. 01-08-00588-CV


KEVIN RITTGER, M.D., Appellant


V.


VIRGINIA LOU DANOS, INDIVIDUALLY AND AS NEXT FRIEND OF RYAN COCHRAN, A MINOR, Appellees





On Appeal from the 55th District Court

Harris County, Texas

Trial Court Cause No. 2005-34257




O P I N I O N

In this interlocutory appeal, appellant, Kevin Rittger, M.D., challenges the trial court’s order denying his motion to dismiss the medical malpractice claims made against him by appellee, Lou Virginia Danos, individually and as next friend of Ryan Cochran, a minor. In his sole issue, Rittger contends that the trial court erred by not dismissing the suit on the ground that Danos submitted expert reports that did not satisfy the requirements of Chapter 74 of the Texas Civil Practice and Remedies Code. We affirm.I. Background

          On May 30, 2003, Danos, who was 28-weeks pregnant with her second child, went to St. John Hospital’s emergency room complaining of right arm numbness. Rittger, the emergency room physician, obtained a CT scan of her head and called for a consultation by Danos’s obstetrician, Dr. Victor Patel. Dr. Patel evaluated Danos and ordered a neurological examination. Before the scheduled neurological exam could take place, Patel discharged Danos with a diagnosis of “generalized anxiety.” Two days later, Danos went to Memorial Hermann Hospital with weakness of her right upper and lower extremities. Medical Professionals there found that she had experienced a left middle cerebral artery (“MCA”) stroke due to a clot at the bifurcation of the left MCA.

          Danos sued Rittger and other healthcare providers for medical negligence. Pursuant to section 74.351 of the Texas Civil Practice and Remedies Code, Danos timely filed expert reports from Dave David, M.D., an obstetrician, and Frank Baker, M.D., an emergency room physician. Dr. David’s report did not address the care provided by Rittger. Rittger objected to the sufficiency of Baker’s report and moved to dismiss. The trial court ruled that the report did not comply with section 74.351 and gave Danos 30 days to cure the deficiency. Within the 30 days, Danos served a new report from Baker as well as a report from John Meyer, M.D., a neurological expert not previously designated. The trial court found that Baker, although qualified to opine on the standard of care and its breach, failed to show the nexus between the negligence and the injury. The trial court further found that, section 74.351(c) did not permit Danos to serve a report from a new expert. The trial court dismissed Danos’s case and awarded Rittger $10,000 in attorney’s fees.

          Danos appealed the dismissal of her case to this court, and a panel of this court affirmed the judgment of the trial court. Danos v. Rittger, 253 S.W.3d 294, 295 (Tex. App.—Houston [1st Dist.] 2007, pet. granted). The Supreme Court reversed, holding that section 74.351(a) allows a claimant to cure a deficiency in a report by serving a report from a separate expert during the 30-day cure period. Danos v. Rittger, 253 S.W.3d 215 (Tex. 2008). The Supreme Court remanded the case to the trial court to consider the adequacy of Dr. Meyer’s expert report. Id. at 215–16. Following an oral hearing, the trial court denied Rittger’s motion to dismiss, and this interlocutory appeal followed.

          On appeal, Rittger reasserts his challenges to the adequacy of the plaintiff’s expert reports, claiming that the reports of Baker and Meyer, considered together or separately, fail to satisfy Chapter 74's requirements. Rittger also seeks remand on the issue of attorney’s fees.

II. Medical Expert Reports

A.      Standard of Review

          We review all section 74.351 rulings under an abuse of discretion standard. Am. Transitional Care Centers v. Palacios, 46 S.W.3d 873, 877 (Tex. 2001). A trial court abuses its discretion if it acts in an arbitrary or unreasonable manner without reference to guiding rules or principles. See Garcia v. Martinez, 988 S.W.2d 219, 222 (Tex. 1999). When reviewing matters committed to the trial court’s discretion, we may not substitute our own judgment for that of the trial court. Walker v. Packer, 827 S.W.2d 833, 839 (Tex. 1992). A trial court does not abuse its discretion merely because it decides a discretionary matter differently than an appellate court would in a similar circumstance. See Downer v. Aquamarine Operators, Inc., 701 S.W.2d 238, 242 (Tex. 1985).

          Although we may defer to the trial court’s factual determinations, we review questions of law de novo. Rittmer v. Garza, 65 S.W.3d 718, 722 (Tex. App.—Houston [14th Dist.] 2001, no pet.). To the extent resolution of the issue before the trial court requires interpretation of the statute itself, we apply a de novo standard. Buck v. Blum, 130 S.W.3d 285, 290 (Tex. App.—Houston [14th Dist.] 2004, no pet.).

          In reviewing whether an expert report complies with Chapter 74.351, we evaluate whether the report “represents a good-faith effort” to comply with the statute. Strom v. Mem’l Hermann Hosp. Sys., 110 S.W.3d 216, 221 (Tex. App.—Houston [1st Dist.] 2003, pet. denied). In making this evaluation, we must look only at the information that is contained within the four corners of the report. Bowie Mem’l Hosp. v. Wright, 79 S.W.3d 48, 53 (Tex. 2002).

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In Re Stacy K. Boone, Pa
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Walker v. Packer
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Downer v. Aquamarine Operators, Inc.
701 S.W.2d 238 (Texas Supreme Court, 1985)

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