Phoebe Putney Memorial Hospital, Inc. v. Jeri v. Pruette

CourtCourt of Appeals of Georgia
DecidedMarch 27, 2014
DocketA14A0044
StatusPublished

This text of Phoebe Putney Memorial Hospital, Inc. v. Jeri v. Pruette (Phoebe Putney Memorial Hospital, Inc. v. Jeri v. Pruette) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Phoebe Putney Memorial Hospital, Inc. v. Jeri v. Pruette, (Ga. Ct. App. 2014).

Opinion

SECOND DIVISION BARNES, P. J., MILLER and RAY, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. http://www.gaappeals.us/rules/

March 27, 2014

In the Court of Appeals of Georgia A13A1833. PRUETTE v. UNGARINO. A14A0044. PHOEBE PUTNEY MEMORIAL HOSPITAL, INC. v. PRUETTE. A14A0045. PRUETTE v. PHOEBE PUTNEY MEMORIAL HOSPITAL, INC. et al.

RAY, Judge.

These appeals arise from a wrongful death action alleging medical negligence

brought by the plaintiff for the death of her mother, who died allegedly as the result

of receiving an overdose of morphine ordered by Dr. Thomas Ungarino and

administered by a nurse employed by Phoebe Putney Memorial Hospital (“Phoebe

Putney”) (collectively, “defendants”). The case proceeded to a jury trial, and the jury

returned a verdict for the plaintiff and against the defendants, jointly and severally.

Dr. Ungarino and Phoebe Putney filed separate motions for new trial, which the trial court granted on the grounds that it had erred as a matter of law in allowing plaintiff’s

expert pulmonologist to offer opinions “in which the issue of informed consent was

injected into the standard of care evidence.” The case was retried, and at the second

trial, the jury absolved Dr. Ungarino but found against Phoebe Putney. Phoebe Putney

filed a motion for new trial from the second trial, which was denied.

For the purposes of appeal, we consolidate Case Nos. A13A1833, A14A0044,

and A14A0045.

In Case No. A13A1833, plaintiff appeals from the trial court’s grant, in a single

order, of both defendants’ motions for new trial after the first trial on the grounds that

the defendants’ expert pulmonologist inserted inadmissible testimony into trial

regarding Dr. Ungarino’s duty to obtain informed consent. In doing so, plaintiff

argues that any objection regarding the impermissible injection of testimony as to

informed consent was waived by defendants’ failure to raise and object to such at

trial, or in the alternative, that the trial court erred because no testimony regarding

informed consent was presented to the trier of fact in this case. In Case No.

A14A0044, Phoebe Putney appealed from the denial of its motion for new trial after

the second trial, alleging that the trial court committed several errors during the trial.

In Case No. A14A0045, plaintiff filed a cross-appeal, arguing (again) that the trial

2 court’s grant of Phoebe Putney’s motion for new trial after the first trial was in error.

Because we find that the trial court correctly granted the motion for new trial after the

first trial as to plaintiff’s case against Dr. Ungarino, but incorrectly granted it as to

Phoebe Putney, we affirm the judgment in part and reverse the judgment in part as to

A13A1833, reverse the judgment in A14A0045, and dismiss Phoebe Putney’s

enumerations of error set forth in A14A0044 as moot.

The grant of a motion for new trial on special grounds involving a question of

law is reviewed by this Court de novo, and this Court will “reverse if the trial court

committed legal error.” (Citations and footnotes omitted.) Govt. Employees Ins. Co.

v. Progressive Casualty Ins.Co., 275 Ga. App. 872, 873-874 (1) (622 SE2d 92)

(2005).

The record shows that the decedent, Janie Vinson, was 79 years old at the time

of her death. In the final years of her life, she suffered from end-stage chronic

obstructive pulmonary disease (“COPD”), a lung disorder that resulted in airway

obstruction and difficulty breathing. On March 7, 2002, Vinson experienced

progressively worsening shortness of breath, was brought to Phoebe Putney, and was

admitted for treatment.

3 During her hospitalization,Vinson was treated by her pulmonologist, Dr.

Mehta, and her primary care doctors at Albany Internal Medicine Group. After

several days in the hospital, her condition began to improve. On the morning of

March 18, 2002, however, Vinson’s condition significantly worsened, and she went

into respiratory distress.

An emergency code was called, and several doctors, including defendant Dr.

Ungarino, responded. Dr. Ungarino, a pulmonary critical care physician, had never

seen Vinson before as a patient and had never been consulted about her treatment or

care during her hospitalization. Vinson’s attending physician, Dr. Kay Kitchen, also

responded to the code and came into the room after Dr. Ungarino. Dr. Ungarino had

been preparing to intubate Vinson, but stopped when Dr. Kitchen informed him of

Vinson’s prior request not to be intubated.

Dr. Kitchen then took over Vinson’s care and, after consulting with Vinson’s

family and Dr. Mehta, her pulmonologist, ordered 2 milligrams of morphine to be

administered to Vinson on an as-needed basis. Dr. Ungarino then reviewed Vinson’s

chart and, without speaking to Dr. Kitchen, Dr. Mehta, the nurse, or Vinson’s family,

changed Vinson’s chart to order that she be given 20 milligrams of morphine in a

single dose. Approximately 40 minutes after the code ended, nurse Linda Hurdle

4 came into the room and administered 20 milligrams to Vinson, per Dr. Ungarino’s

order. Vinson soon lost consciousness and died approximately three hours later.

Plaintiff filed suit against Dr. Ungarino and Phoebe Putney for the wrongful

death of her mother. She alleged that Dr. Ungarino violated the standard of care by

ordering the rapid infusion of 20 milligrams of morphine into an end-stage COPD

patient and that administration of such a high dosage caused Vinson’s death.

Plaintiff further alleged that Vinson’s nurse, Linda Hurdle, violated the nursing

standard of care by administering the dose of morphine and that Phoebe Putney could

be held vicariously liable for her actions.

The case proceeded to a jury trial, and the jury returned a verdict for the

plaintiff and against the defendants, jointly and severally. In a single order, the trial

court granted the defendants’ separate motions for new trial on the grounds that it had

erred as a matter of law in allowing plaintiff’s expert to offer opinions “in which the

issue of informed consent was injected into the standard of care evidence,” and that

plaintiff improperly presented arguments involving the doctrine of informed consent

during her opening statement and closing arguments. The case was retried, leading

to a verdict on the plaintiff’s claims in favor of Dr. Ungarino, but against Phoebe

Putney. The trial court denied Phoebe Putney’s second motion for new trial.

5 Case No. A13A1833

In Case No. A13A1833, plaintiff appeals from the trial court’s grant of the

defendants’ motions for new trial.

1. The Law of Informed Consent. Georgia law does not recognize a common

law duty to inform patients of the risks of medical procedures. Blotner v. Doreika,

285 Ga. 481, 481-482 (1) (678 SE2d 80) (2009). By statute, however, any person who

undergoes any surgical procedure under general anaesthesia, spinal anesthesia, major

regional anesthesia, or any person who undergoes certain diagnostic procedures, must

consent to the procedure. OCGA § 31-9-6.1 (a). This consent must be informed,

meaning that the medical professional must fully inform the patient of the material

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