Prince v. Beaufort Memorial Hospital

Court of Appeals of South Carolina·Decided March 3, 2008·No. 2008-UP-139·Unpublished

Opinion

THIS OPINION HAS NO PRECEDENTIAL VALUE.  IT SHOULD NOT BE CITED OR RELIED ON AS PRECEDENT IN ANY PROCEEDING EXCEPT AS PROVIDED BY RULE 239(d)(2), SCACR.

THE STATE OF SOUTH CAROLINA
In The Court of Appeals

Danny R. Prince, Respondent,

v.

Beaufort Memorial Hospital and its Employees, Servants and Agents, Appellants.


Appeal From Beaufort County
 Alexander S. Macaulay, Circuit Court Judge


Unpublished Opinion No. 2008-UP-139
Heard January 8, 2008 – Filed March 3, 2008


REVERSED AND REMANDED


Mary Bass Lohr, of Beaufort, for Appellant.

T. Wayne Yarbrough, of Bluffton, for Respondent.

PER CURIAM:  In this personal injury action, Beaufort Memorial Hospital (Hospital) appeals the grant of a new trial to Danny R. Prince on the ground that its Quality Assurance Committee file should have been made available to Prince during the prior trial.  We reverse and remand.

FACTS AND PROCEDURAL HISTORY

On February 13, 1999, Hospital admitted Prince into a fourth-floor room for treatment of job-related injuries.  Initially, Prince was a compliant patient and exhibited no signs of psychotic behavior.  Sometime after 10:30 p.m. on February 17, 1999, however, Prince apparently experienced a psychotic hallucination in his hospital room and was found by Hospital staff at 11:20 p.m. on the roof of a lower floor with injuries to his ankles and head.  Although Prince did not remember anything from the incident, the window in his room appeared to have been forced open. 

On February 15, 2001, Prince brought a negligence action against Hospital and Hospital’s servants and agents.  At issue in the case was how and why Prince ended up on the roof and whether or not the defendants could or should have prevented the incident.

During discovery, Prince sought to obtain a copy of a file generated by Hospital’s Quality Assurance Committee pursuant to the Committee’s investigation of the incident.  Instead, however, Hospital provided a summary of expected witness testimony and refused to give Prince the file, claiming it was protected under South Carolina Code sections 40-71-10 and 40-71-20.[1]  Consequently, Prince filed a motion to compel discovery of the complete Quality Assurance Committee file.  The trial court denied the motion, and a jury ultimately returned a verdict in Hospital’s favor. 

Following the denial of his motions for judgment notwithstanding the verdict and a new trial, Prince appealed to this Court, contending the trial court erred in finding the contents of the file were not subject to discovery.  In an unpublished opinion, this Court held that, although Hospital’s Quality Assurance Committee was within the purview of section 40-71-10 to the extent the Committee operated pursuant to bylaws approved by Hospital and the information acquired by the Committee was protected under section 40-71-20, “the nature of the case demands an in camera review of the file.”  Prince v. Beaufort Mem’l Hosp., Op. No. 05-UP-602 (Ct. App. 2006) (S.C. Ct. App. filed April 11, 2006).  Accordingly, this Court reversed the denial of Prince’s motion for a new trial and remanded the case to the trial court for an in camera review of the file, with the following instructions:

[T]he circuit court shall conduct an in camera review of the committee file.  Using its discretion, the court shall decide whether the file warrants confidentiality.  If the circuit court determines that the file contains relevant evidence which is not protected by the confidentiality statute, then it shall declare a new trial.  Alternatively, if the circuit court determines that there is no relevant evidence in the committee file or that the file is not entitled to protections of the confidentiality statute, then the original denial of the new trial and JNOV motion would be affirmed.

After the required in camera review of the Quality Assurance Committee file, the trial court found Hospital had waived the protections of section 40-71-20 and declared a new trial.  The trial court based this finding on its observation that Hospital “used certain witness statement summaries from this committee file in order to answer Interrogatories propounded by the Plaintiff.”  Using the law on waiver of the attorney-client privilege as a guide, the trial court further held that, once the privilege is waived, “it is clear that it is waived as to all communications on the same subject matter.” 

Hospital moved for reconsideration, arguing among other things Prince did not raise the issue of waiver in his initial appeal and the trial court lacked authority to raise the issue sua sponte on remand.  The trial court declined to amend its prior order.  As to Hospital’s argument that Prince failed to preserve the issue of waiver in his appeal, the trial court held Prince “raised the issue of waiver specifically several times, and, more importantly, . . . the issue of waiver is so intertwined with the issue of confidentiality of the file that it was inherently preserved for review.”  This appeal followed.

STANDARD OF REVIEW

“The decision whether to grant a new trial is left to the sound discretion of the trial court and generally will not be disturbed on appeal.”  Dropkin v. Beach Villa Condominium Ass’n, 373 S.C. 360, 363, 644 S.E.2d 808, 809 (Ct. App. 2007) (citing Rush v. Blanchard, 310 S.C. 375, 380, 426 S.E.2d 802, 805 (1993)).  “An abuse of discretion occurs when the trial court’s findings are wholly unsupported by the evidence or the conclusions reached are controlled by an error of law.”  Wright v. Craft, 372 S.C. 1, 36, 640 S.E.2d 486, 505 (Ct. App. 2006).

LAW/ANALYSIS

1.  Hospital first argues that Prince, in his initial appeal to this court, failed to challenge the rejection of his argument at trial that Hospital had waived its right to assert the Quality Assurance Committee file was confidential under section 40-71-20 and is therefore barred by the law of the case doctrine from a finding on remand that Hospital waived its right to assert that the Quality Assurance Committee file was confidential.  We agree.

As a general rule, an unchallenged ruling, right or wrong, is the law of the case.  Ex parte Morris, 367 S.C. 56, 65, 624 S.E.2d 649, 654 (2006).  “Any unappealed portion of the trial court’s judgment is law of the case and must be affirmed.”  Rumpf v. Massachusetts Mut. Life Ins. Co., 357 S.C. 386, 398, 593 S.E.2d 183, 189 (Ct. App. 2004); see also ML-Lee Acquisition Fund, L.P. v. Deloitte & Touche, 327 S.C. 238, 241, 489 S.E.2d 470

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