Mendez-Caton v. Caribbean Family Health Center

CourtDistrict Court, E.D. New York
DecidedSeptember 30, 2024
Docket1:19-cv-01599
StatusUnknown

This text of Mendez-Caton v. Caribbean Family Health Center (Mendez-Caton v. Caribbean Family Health Center) is published on Counsel Stack Legal Research, covering District Court, E.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mendez-Caton v. Caribbean Family Health Center, (E.D.N.Y. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK ----------------------------------------------------------------x STACEY MENDEZ-CATON and : ALISTER CATON, : : : Plaintiffs, : MEMORADUM & ORDER -against- : 19-cv-1599 (DLI)(TAM) : UNITED STATES OF AMERICA, : NYU LANGONE HEALTH, and : JENNA SILVERSTEIN, M.D., : : Defendants. : ----------------------------------------------------------------x

DORA L. IRIZARRY, United States District Judge: This medical malpractice action, resulting from alleged negligence in the provision of post- partum care, is before the Court pursuant to 28 U.S.C. § 2675 and 28 U.S.C. § 1346. Am. Compl., Dkt. Entry No. 75. The parties certified the close of discovery on March 31, 2022. Joint Letter Certifying the Close of Discovery, Dkt. Entry No. 58. Before the Court are the parties’ cross- motions in limine, seeking to preclude the testimony of expert witnesses pursuant to Fed. R. of Evidence 702 (“Rule 702”). Stacey Mendez-Caton and Alister Caton (“Plaintiffs”) move to preclude the testimony of the United States of America’s (the “Government”) medical expert, Dr. Ifath Hoskins, as well as the testimony of NYU Langone Health’s and Dr. Jenna Silverstein’s (“NYU Defendants”) medical expert, Dr. Thomasina Ellison. See, Pls.’ Mot. in Lim. (“Pls.’ MIL”), Dkt. Entry No. 118-2. The Government and NYU Defendants each oppose Plaintiffs’ motion. See, USA Opp’n to Pls.’ MIL (“USA Opp’n”), Dkt. Entry No. 120; NYU Defs.’ Opp’n to Pls.’ MIL (“NYU Opp’n”), Dkt. Entry No. 119. Plaintiffs replied to each opposition. See, Pls.’ Reply to NYU (“Reply to NYU”), Dkt. Entry No. 121-1; Pls.’ Reply to USA Opp’n (“Reply to USA”), Dkt. Entry No. 121-2. expert witness, Dr. Burt Greenburg. See, USA Mot. in Lim. (“USA MIL”), Dkt. Entry No. 122; NYU Mot. in Lim. (“NYU MIL”), Dkt. Entry No. 125. Plaintiffs opposed both motions. See, Pls.’ Opp’n to USA MIL (“Pls.’ USA Opp’n”), Dkt. Entry No. 124; Pls.’ Opp’n to NYU MIL (“Pls.’ NYU Opp’n”); Dkt. Entry No. 128. The Government and NYU Defendants replied in

support of their respective motions. See, USA Reply in Supp. of USA MIL (“USA Reply”), Dkt. Entry No. 129; NYU Reply in Supp. of NYU MIL (“NYU Reply”), Dkt. Entry No. 126. BACKGROUND On September 5, 2017, Stacey Mendez-Caton (“Mendez-Caton”) was admitted to NYU Langone Health/LM located at 150 55th Street, Brooklyn, New York pregnant and in labor. Am. Compl. at ¶ 14. After giving birth by Caesarean section, Mendez-Caton suffered an injury to her skin during post-partum care. Id. As Jenna Silverstein, M.D. (“Dr. Silverstein”), the resident-in- charge, attempted to remove the dressing tape that was applied to her skin, “she removed much of the skin with the tape.” Id. Plaintiffs filed this action asserting negligence in the medical care Mendez-Caton received.

Id. at ¶¶ 15-18. Plaintiffs also make claim for loss of consortium. Id. at ¶¶ 19-21. Plaintiffs allege that Mendez-Caton’s “permanent and severe injuries,” including scarring, resulted from Defendants’ failure to adhere to appropriate standards of care, failure to provide sufficient post- partum care, failure to listen to Mendez-Caton’s statements of pain and injury, and failure to consult with specialists prior to proceeding. Id. at ¶¶ 16-17. LEGAL STANDARD Federal Rule of Evidence 104(a) provides that the admissibility of expert testimony is a preliminary question of law for the court to determine. Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579, 592 (1993). The proponent of the testimony bears the burden of demonstrating its admissibility by a preponderance of the evidence. See, Berk v. St. Vincent’s Hosp. and Med. Ctr., 380 F. Supp.2d 334, 349 (S.D.N.Y. Aug. 11, 2005) (citations omitted). The admissibility of expert testimony is governed by Rule 702 of the Federal Rules of Evidence. See, Nimely v. City of New York, 414 F.3d 381, 395 (2d Cir. 2005). Rule 702 sets forth

a three-step inquiry to determine whether the testimony of a party’s proffered expert should be deemed admissible. First, the court must review the relevance of the proposed expert’s testimony to determine whether the conclusions it draws will aid the factfinder in answering the questions at issue in the case. Berk v. St. Vincent’s Hosp. and Med. Ctr., 380 F. Supp.2d 334, 350 (S.D.N.Y. Aug. 11, 2005). Second, the court must investigate the expert’s compliance with the provision of Fed. R. Evid. 702 that requires an expert to be “qualified as an expert by knowledge, skill, experience, training, or education.” Nimely, 414 F.3d at 395 n. 11. Finally, the court must consider whether the testimony is reliable. To be reliable, expert testimony must be based on sufficient facts or data, and it must be the product of reliable, properly applied principles or methodology. “[P]roponents ‘do not have to demonstrate to the judge by a

preponderance of the evidence that the assessments of their experts are correct, they only have to demonstrate by a preponderance of evidence that their opinions are reliable. . . . [t]he evidentiary requirement of reliability is lower than the merits standard of correctness.’” Advisory Committee Note to the 2000 amendment to Rule 702, quoting In re Paoli R.R. Yard PCB Litigation, 35 F.3d 717, 744 (3d Cir. 1994). DISCUSSION

As an initial matter, it is helpful to clarify on which issues in this case a medical expert’s testimony is needed to aid the factfinder, and, therefore, what type of expertise a proposed expert should possess. From this common foundation, evaluation of each proposed expert’s qualifications and proffered testimony can proceed. Under New York Law, medical malpractice requires a showing of three elements: (1) the standard of care in the locality where the treatment occurred; (2) that the defendants breached that standard of care; and (3) that the breach of the standard was the proximate cause of injury.” In most cases, each element “must be established by expert medical opinion.” Urena v. Yan Wolfson,

M.D., 2012 WL 958529, at *4 (E.D.N.Y. Mar. 20, 2012) (citing Hogan v. A.O. Fox Mem. Hosp., 346 F. App'x 627, 630 (2d Cir. 2009) (summary order)). “[I]t is well-established that each element [of medical malpractice] must be established by expert medical opinion unless the deviation from a proper standard of care is so obvious as to be within the understanding of an ordinary layperson.” Kawache v. United States, 2011 WL 441684, at *14 (E.D.N.Y. Feb. 7, 2011), aff'd, 471 F. App'x 10 (2d Cir. 2012) (citing Sitts v. United States, 811 F.2d at 739–40 (2d Cir. 1987)). Here, the malpractice Plaintiffs complain of is Defendants’ failure to adhere to the standard of care in the post-surgical use (including removal) of surgical bandages and tape following Mendez-Caton’s Cesarean section. Am. Compl. at ¶¶ 14, 16. Therefore, the relevant expertise is knowledge of the standard of care in the post-surgical use of these surgical bandages and tape in

September 2017.

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Related

Daubert v. Merrell Dow Pharmaceuticals, Inc.
509 U.S. 579 (Supreme Court, 1993)
Kawache v. United States
471 F. App'x 10 (Second Circuit, 2012)
In Re Paoli Railroad Yard PCB Litigation
35 F.3d 717 (Third Circuit, 1994)
Rosco, Inc. v. Mirror Lite Co.
506 F. Supp. 2d 137 (E.D. New York, 2007)
In Re Zyprexa Products Liability Litigation
489 F. Supp. 2d 230 (E.D. New York, 2007)
Berk v. St. Vincent's Hospital & Medical Center
380 F. Supp. 2d 334 (S.D. New York, 2005)
Nimely v. City of New York
414 F.3d 381 (Second Circuit, 2005)

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Bluebook (online)
Mendez-Caton v. Caribbean Family Health Center, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mendez-caton-v-caribbean-family-health-center-nyed-2024.