Oral James, M.D. v. Ricardo Noyola, Individually and as Representative of the Estate of Consuelo Noyola, Pedro Noyola, and Gloria N. Chapa

CourtCourt of Appeals of Texas
DecidedAugust 29, 2008
Docket13-08-00184-CV
StatusPublished

This text of Oral James, M.D. v. Ricardo Noyola, Individually and as Representative of the Estate of Consuelo Noyola, Pedro Noyola, and Gloria N. Chapa (Oral James, M.D. v. Ricardo Noyola, Individually and as Representative of the Estate of Consuelo Noyola, Pedro Noyola, and Gloria N. Chapa) 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.

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Oral James, M.D. v. Ricardo Noyola, Individually and as Representative of the Estate of Consuelo Noyola, Pedro Noyola, and Gloria N. Chapa, (Tex. Ct. App. 2008).

Opinion



COURT OF APPEALS



THIRTEENTH DISTRICT OF TEXAS



CORPUS CHRISTI - EDINBURG



NUMBERS 13-07-00713-CV & 13-08-00183-CV



HARRY E. BUTTERS, M.D., Appellant,

v.



RICARDO NOYOLA, INDIVIDUALLY

AND AS REPRESENTATIVE OF THE

ESTATE OF CONSUELO NOYOLA,

PEDRO NOYOLA, AND GLORIA N. CHAPA, Appellees.



NUMBERS 13-07-00765-CV & 13-08-00184-CV



ORAL JAMES, M.D., Appellant,







NUMBERS 13-08-00038-CV & 13-08-00203-CV



LUIS LEYTON GONZALEZ, M.D., Appellant,







On appeal from the 404th District Court of Cameron County, Texas.

MEMORANDUM OPINION



Before Justices Rodriguez, Garza, and Vela

Memorandum Opinion by Justice Garza



This is an accelerated interlocutory appeal from the trial court's denial of motions to dismiss health care liability claims. See Tex. Civ. Prac. & Rem. Code Ann. § 51.014(a)(9) (Vernon 2008), § 74.351(b) (Vernon Supp. 2007); see also Tex. R. App. P. 28.1. Appellees, Ricardo Noyola, individually and as representative of the estate of Consuelo Noyola, Pedro Noyola (collectively "the Noyolas"), and Gloria N. Chapa, filed suit against appellants, Oral James, M.D., Harry E. Butters, M.D., and Luis Leyton Gonzalez, M.D., for wrongful death and medical malpractice in connection with Consuelo's death. By one issue, appellants argue that the trial court abused its discretion in denying their motions to dismiss and in failing to award reasonable attorney's fees and costs of court. Because appellees' expert report is inadequate, we reverse the orders of the trial court and remand for proceedings consistent with this opinion.

I. Background

Dr. James performed a colonoscopy on Consuelo Noyola at Harlingen Medical Center on January 20, 2006. The colonoscopy was aborted, allegedly due to poor preparation by Consuelo. Dr. James then ordered a barium enema to be performed the same day. Later that day, Dr. Butters performed the barium enema. On January 22, 2006, Consuelo underwent surgery to repair a bowel perforation. The Loyolas alleged that either the colonoscopy or the barium enema caused the bowel perforation and that Consuelo subsequently developed sepsis and died because she did not receive immediate treatment to repair the perforation.

The Noyolas filed suit against appellants on September 7, 2007, claiming that Dr. James was negligent for ordering the barium enema, Dr. Butters was negligent for performing the barium enema, and Dr. Gonzalez was negligent for failing to order surgery on January 21, 2006. To satisfy the statutory requirement, the Noyolas served appellants with an expert report by Isaac Raijman, M.D. See Tex. Civ. Prac. & Rem. Code Ann. § 74.351(a) (Vernon Supp. 2007). Appellants filed objections to the sufficiency of the report and motions to dismiss. The trial court denied the motions.

On November 27, 2007, appellees filed their first amended petition with Chapa, Consuelo's daughter, added as a wrongful death plaintiff. Chapa served appellants with the same report from Dr. Raijman. Appellants then filed supplemental motions to dismiss as to both the Noyolas and Chapa, again claiming that the report was inadequate. The trial court denied those motions as well. Appellants filed a notice of interlocutory appeal challenging the trial court's denial of their motions. (1)

II. Adequacy of Expert Report

By their sole issue, appellants argue that because Dr. Raijman's expert report was inadequate, the trial court erred by denying their motions to dismiss and by not awarding attorney's fees and court costs. (2)

We agree.

A. Standard of Review

We review a trial court's order denying a motion to dismiss for failure to comply with the expert report requirement under an abuse of discretion standard. NCED Mental Health, Inc. v. Kidd, 214 S.W.3d 28, 32 (Tex. App.-El Paso 2006, no pet.) (applying abuse of discretion standard to trial court's denial of motion to dismiss); Kendrick v. Garcia, 171 S.W.3d 698, 702 (Tex. App.-Eastland 2005, pet. denied) (same); see Am. Transitional Care Ctrs. of Tex., Inc. v. Palacios, 46 S.W.3d 873, 878 (Tex. 2001) (applying abuse of discretion standard to trial court's granting of motion to dismiss). A trial court abuses its discretion if it acts in an arbitrary or unreasonable manner or without reference to any guiding rules or principles. Downer v. Aquamarine Operators, Inc., 701 S.W.2d 238, 241-42 (Tex. 1985). When reviewing matters committed to the trial court's discretion, we may not substitute our own judgment for that of the trial court. Bowie Mem'l Hosp. v. Wright, 79 S.W.3d 48, 52 (Tex. 2002). However, a trial court has no discretion in determining what the law is or in applying the law to the facts. Walker v. Packer, 827 S.W.2d 833, 840 (Tex. 1992); Baylor Univ. Med. Ctr. v. Biggs, 237 S.W.3d 909, 916 (Tex. App.-Dallas 2007, pet. denied). A clear failure by the trial court to analyze or apply the law correctly will constitute an abuse of discretion. Walker, 827 S.W.2d at 840.

B. Applicable Law

Medical malpractice plaintiffs must provide each defendant physician and health care provider an expert report containing the expert's curriculum vitae and

a fair summary of the expert's opinions as of the date of the report regarding applicable standards of care, the manner in which the care rendered by the physician or health care provider failed to meet the standards, and the causal relationship between that failure and the injury, harm, or damages claimed.



Tex. Civ. Prac. & Rem. Code Ann. § 74.351(r)(6) (Vernon Supp. 2007); Bowie Mem'l Hosp, 79 S.W.3d at 51; see Palacios, 46 S.W.3d at 877.

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Leland v. Brandal
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998 S.W.2d 882 (Texas Supreme Court, 1999)
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Lenger v. Physician's General Hospital, Inc.
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Downer v. Aquamarine Operators, Inc.
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Oral James, M.D. v. Ricardo Noyola, Individually and as Representative of the Estate of Consuelo Noyola, Pedro Noyola, and Gloria N. Chapa, Counsel Stack Legal Research, https://law.counselstack.com/opinion/oral-james-md-v-ricardo-noyola-individually-and-as-texapp-2008.