Postell v. Hankla

728 S.E.2d 886, 317 Ga. App. 86, 2012 Fulton County D. Rep. 2025, 2012 WL 2301652, 2012 Ga. App. LEXIS 539
CourtCourt of Appeals of Georgia
DecidedJune 19, 2012
DocketA12A0703
StatusPublished
Cited by6 cases

This text of 728 S.E.2d 886 (Postell v. Hankla) 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
Postell v. Hankla, 728 S.E.2d 886, 317 Ga. App. 86, 2012 Fulton County D. Rep. 2025, 2012 WL 2301652, 2012 Ga. App. LEXIS 539 (Ga. Ct. App. 2012).

Opinion

Mikell, Presiding Judge.

In the first appearance of this medical malpractice case before this Court,1 we summarized the underlying facts as follows:

Zamarion Everett sustained a permanent brachial plexus injury2 during his birth in 2003. His mother, Anita Jackson [Postell], filed the instant medical malpractice action, individually and as next friend of Everett, against Certified Nurse Midwife Vickie Hankla, who attended the birth, and Hankla’s employer, Southern OB-GYN Associates, P.C. (collectively “Hankla”). [Postell] argued that Hankla breached the standard of care during delivery when she applied lateral traction3 with enough force to cause Zamarion’s injury during her attempts to deliver him during an obstetrical complication known as shoulder dystocia, which occurs [87]*87when an infant’s shoulders become lodged in the mother’s pelvis after delivery of the head.4

On remand, the case was tried before a jury, which found for the defense. The trial court entered judgment on the jury’s verdict, and Postell5 appeals, contending that the trial court erred in denying her motion to exclude the testimony of Hankla’s expert witness, Dr. Sandra Brickman, and in restricting her cross-examination of Hank-la’s expert witness, Dr. Thomas Moseley, as to his financial interest in the outcome of the trial. We conclude that Brickman, a medical doctor, was not qualified under OCGA § 24-9-67.1 (c) (2) (D) to testify as to the standard of care of Hankla, a nurse midwife. Because the erroneous admission of Brickman’s testimony as to Hankla’s standard of care was not harmless, we reverse the judgment and remand for a new trial.

“The issue of the admissibility or exclusion of expert testimony rests in the broad discretion of the court, and consequently, the trial court’s ruling thereon cannot be reversed absent an abuse of discretion.”6

1. Postell argues that Brickman was not qualified to testify as an expert witness' in a medical malpractice action against a nurse midwife because Brickman had not supervised, taught, or instructed nurse midwives during three of the five years preceding Zamarion’s birth, and therefore Brickman did not satisfy the requirements set forth in OCGA § 24-9-67.1 (c) (2) (D). Hankla does not contend that Brickman supervised, taught, or instructed nurse midwives during the requisite period; instead, Hankla argues that because Brickman met the “active practice” requirement found in OCGA § 24-9-67.1 (c) (2) (A), she did not need to meet the further requirements of subparagraph (D). This argument, however, is not supported by the language of the statute or by prior rulings of this Court.

OCGA § 24-9-67.1 (c) provides, in pertinent part:

[I]n professional malpractice actions, the opinions of an expert, who is otherwise qualified as to the acceptable standard of conduct of the professional whose conduct is at issue, shall be admissible only if, at the time the act or omission is [88]*88alleged to have occurred, such expert:
(1) Was licensed by an appropriate regulatory agency... at such time; and
(2) In the case of a medical malpractice action, had actual professional knowledge and experience in the area of practice or specialty in which the opinion is to be given as the result of having been regularly engaged in:
(A) The active practice of such area of specialty of his or her profession for at least three of the last five years ... ;or
(B) The teaching of his or her profession for at least three of the last five years . . . ; and
(C) Except as provided in subparagraph (D) of this paragraph: (i) [i]s a member of the same profession ...; and
(D) Notwithstanding any other provision of this Code section, an expert who is a physician and, as a result of having, during at least three of the last five years immediately preceding the time the act or omission is alleged to have occurred, supervised, taught, or instructed . . . nurse midwives, . . . has knowledge of the standard of care of that health care provider under the circumstances at issue shall be competent to testify as to the standard of that health care provider. However, a . . . nurse midwife . . . shall not be competent to testify as to the standard of care of a physician.7

As this Court has explained previously, the word “or” connecting subparagraphs (2) (A) and (2) (B), followed by the word “and” connecting subparagraphs (2) (B) and (2) (C), means that “a medical expert must show either ‘active practice’ or ‘teaching’ for ‘at least three of the last five years,’but that whichever of these may be the case, the expert must also be ‘a member of the same profession’ as the person whose performance he is evaluating.”8 If the expert is not a member of the same profession, then the expert must qualify under subparagraph (D) in order to testify against the defendant provider. Hankla’s expert, Brickman, a medical doctor, is not in the same profession as [89]*89Hankla, a nurse midwife.9 Therefore, unless Brickman qualified under subparagraph (D), she was not competent to testify as to Hankla’s standard of care.

Subparagraph (D) of OCGA § 24-9-67.1 (c) (2) allows a medical doctor to testify as to the standard of care of a nurse midwife where the doctor has knowledge of the nurse midwife’s standard of care as the result of having “supervised, taught, or instructed” nurse midwives during the requisite time period. The record reflects, and Hankla makes no contrary contention, that Brickman did not supervise, teach, or instruct nurse midwives during at least three of the last five years immediately preceding Zamarion’s birth on August 18, 2003, the time the negligence is alleged to have occurred. Brickman completed her residency in June 2000 and began the private practice of medicine in July or August of that year. She testified that she had not supervised or worked with nurse midwives since leaving her residency and entering private practice, that is, from August 2000 until after Zamarion’s birth in August 2003. Because she had not supervised, taught, or instructed midwives during the three years prior to Zamarion’s birth, Brickman did not meet the requirements set forth in subparagraph (D) and therefore was not qualified to testify as to the standard of care of a nurse midwife. In ruling otherwise, the trial court abused its discretion.10

Moreover, we cannot deem this error harmless, and Hankla does not contend otherwise.

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749 S.E.2d 726 (Supreme Court of Georgia, 2013)
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Cite This Page — Counsel Stack

Bluebook (online)
728 S.E.2d 886, 317 Ga. App. 86, 2012 Fulton County D. Rep. 2025, 2012 WL 2301652, 2012 Ga. App. LEXIS 539, Counsel Stack Legal Research, https://law.counselstack.com/opinion/postell-v-hankla-gactapp-2012.