Nancy Traut v. William R. Beaty, M.D.

CourtCourt of Appeals of Texas
DecidedApril 26, 2002
Docket06-01-00007-CV
StatusPublished

This text of Nancy Traut v. William R. Beaty, M.D. (Nancy Traut v. William R. Beaty, M.D.) 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
Nancy Traut v. William R. Beaty, M.D., (Tex. Ct. App. 2002).

Opinion



In The

Court of Appeals

Sixth Appellate District of Texas at Texarkana



______________________________


No. 06-01-00007-CV
______________________________


NANCY TRAUT, Appellant


V.


WILLIAM R. BEATY, M.D., Appellee





On Appeal from the 102nd Judicial District Court
Bowie County, Texas
Trial Court No. 98C0869-102





Before Cornelius, C.J., Grant and Ross, JJ.
Opinion by Chief Justice Cornelius


O P I N I O N


Nancy Traut appeals from a summary judgment granted in favor of William Beaty, M.D. Traut sued Beaty, (1) alleging negligence and negligence based on res ipsa loquitur when part of a wire, about one centimeter long, was left in Traut's left breast after Beaty performed a hook-wire needle localization procedure on her. (2) Sometime later, Beaty filed a motion for sanctions under Tex. Rev. Civ. Stat. Ann. art. 4590i, § 13.01 (Vernon Supp. 2002), contending that Traut failed to file the expert report required by the statute. The trial court ordered Traut's cause of action for negligence dismissed with prejudice and ordered Traut to produce an expert report within 120 days.

After the period specified in the trial court's order expired, Beaty filed a motion for summary judgment, a supplemental motion for summary judgment, and a new motion for sanctions. In his summary judgment motions, Beaty contended res ipsa loquitur was inapplicable as a matter of law. He also contended there was no evidence that his negligence caused Traut's injury. In his motion for sanctions, Beaty contended Traut failed to provide the expert report the trial court had previously ordered.

The trial court ordered Traut's cause of action for negligence based on res ipsa loquitur dismissed with prejudice and granted Beaty's motions for summary judgment. On appeal, Traut contends the trial court erred in granting Beaty's second motion for sanctions and his motions for summary judgment. (3)

The Medical Liability and Insurance Improvement Act, Tex. Rev. Civ. Stat. Ann. art. 4590i, § 13.01(d)(1), requires a plaintiff, within 180 days of filing a claim, either to furnish one or more expert reports to counsel for each physician or health care provider against whom the plaintiff asserts the claim or to nonsuit the case. An expert report is not required for any issue other than an issue related to liability or causation. Tex. Rev. Civ. Stat. Ann. art. 4590i, § 13.01(j).

If the plaintiff fails to provide an expert report or to nonsuit the case within the time required, the trial court must, on the defendant's motion, award as sanctions (1) the defendant's reasonable attorney's fees and court costs; (2) the forfeiture of the plaintiff's cost bond to the extent necessary to pay the award; and (3) the dismissal of the plaintiff's action with prejudice. Tex. Rev. Civ. Stat. Ann. art. 4590i, § 13.01(e). The trial court may grant one thirty-day extension of the deadline for filing the expert report on a showing of good cause after motion and a hearing. Tex. Rev. Civ. Stat. Ann. art. 4590i, § 13.01(f). We apply an abuse of discretion standard when reviewing a dismissal under Article 4590i, § 13.01, reversing only if the trial court acts unreasonably or arbitrarily. Am. Transitional Care Ctrs. of Tex., Inc. v. Palacios, 46 S.W.3d 873, 877 (Tex. 2001).

As a general rule, a plaintiff has no cause of action against a doctor for malpractice, either in diagnosis or treatment, unless he proves by a doctor of the same school of practice as the defendant that the diagnosis or treatment complained of was negligence and that such negligence was a proximate cause of the plaintiff's injuries. Williams v. Bennett, 610 S.W.2d 144, 146 (Tex. 1980). Ordinarily, expert testimony is required to establish the governing standard of care, and to determine whether the standard has been breached. Ocomen v. Rubio, 24 S.W.3d 461, 466 (Tex. App.-Houston [1st Dist.] 2000, no pet.); McCombs v. Children's Med. Ctr. of Dallas, 1 S.W.3d 256, 259 (Tex. App.-Texarkana 1999, pet. denied).

Res ipsa loquitur, meaning "the thing speaks for itself," is an evidentiary rule applied when the circumstances surrounding an accident are sufficient to support an inference of negligence. Haddock v. Arnspiger, 793 S.W.2d 948, 950 (Tex. 1990). Res ipsa loquitur applies when (1) the character of the accident is such that it would not ordinarily occur in the absence of negligence, and (2) the instrumentality causing the injury is shown to have been under the management and control of the defendant.

For health care liability claims, res ipsa loquitur applies only in those cases to which it has been applied as of the effective date of the Medical Liability and Insurance Improvement Act, i.e., August 29, 1977. Tex. Rev. Civ. Stat. Ann. art. 4590i, § 7.01 (Vernon Supp. 2002); see also Haddock v. Arnspiger, 793 S.W.2d at 950. At the time the Act was enacted, Texas courts generally recognized res ipsa loquitur was inapplicable in medical malpractice cases, except when the nature of the alleged malpractice and injuries are plainly within the common knowledge of lay people, such as negligence in the use of mechanical instruments, operating on the wrong portion of the body, or leaving surgical instruments or sponges in the body. Haddock v. Arnspiger, 793 S.W.2d at 951. Further, a plaintiff may not automatically rely on res ipsa loquitur in every medical malpractice case involving the use of a mechanical instrument, but only in those cases where the use of the mechanical instrument is within the common knowledge of lay people. Id. In Haddock, for example, the Texas Supreme Court held that the use of a flexible colonoscope to perform a proctological examination was not within the common knowledge of lay people. Id. at 954.

Beaty contends this is not a proper case for the application of res ipsa loquitur. The trial court granted Beaty's motion for summary judgment. The judgment was based on Beaty's contention that res ipsa loquitur did not apply. However, reviewing the summary judgment proof, we conclude that the trial court erred because Beaty's deposition testimony is sufficient to create a fact question on whether he conceded he breached the standard of care, notwithstanding whether res ipsa loquitur applies. In his deposition, Beaty testified:

Q. And then somehow that piece of wire broke off while you were taking the wire out?



A. Correct.



Q. And ordinarily you would take all the wire out?





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