Rhea Peralta v. Bradley J. Blakely, M.D.

CourtCourt of Appeals of Washington
DecidedDecember 20, 2022
Docket38616-3
StatusUnpublished

This text of Rhea Peralta v. Bradley J. Blakely, M.D. (Rhea Peralta v. Bradley J. Blakely, M.D.) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rhea Peralta v. Bradley J. Blakely, M.D., (Wash. Ct. App. 2022).

Opinion

FILED DECEMBER 20, 2022 In the Office of the Clerk of Court WA State Court of Appeals, Division III

COURT OF APPEALS, DIVISION III, STATE OF WASHINGTON

RHEA PERALTA, individually and as ) No. 38616-3-III Personal Representative of the Estate ) of MIGUEL ANGEL PERALTA; and ) as Guardian of their minor children, ) L. PERALTA and S.M. PERALTA, ) ORDER DENYING MOTION ) FOR RECONSIDERATION ) AND WITHDRAWING OPINION Appellants, ) FILED NOVEMBER 8, 2022 ) v. ) ) BRADLEY J. BLAKLEY, M.D., and ) JANE DOE BLAKLEY; EMERGENCY ) ASSOCIATES OF YAKIMA, PLLC; ) YAKIMA VALLEY MEMORIAL ) HOSPITAL ASSOCIATION d/b/a ) VIRGINIA MASON MEMORIAL ) HOSPITAL, a/k/a YAKIMA VALLEY ) ) MEMORIAL, ) ) Respondents, ) ) JOHN DOES 1-10, ) ) Defendants. )

THE COURT has considered respondent’s motion for reconsideration and is of the opinion the motion should be denied. Therefore, No. 38616-3-III Page 2

IT IS ORDERED, the motion for reconsideration of this court’s decision of November 8, 2022 is hereby denied.

IT IS FURTHER ORDERED the opinion filed November 8, 2022 is withdrawn and a new opinion will be filed herewith.

PANEL: Staab, Pennell, Lawrence-Berrey

FOR THE COURT:

___________________________________ LAUREL SIDDOWAY Chief Judge FILED DECEMBER 20, 2022 In the Office of the Clerk of Court WA State Court of Appeals, Division III

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE

RHEA PERALTA, individually and as ) No. 38616-3-III Personal Representative of the Estate ) of MIGUEL ANGEL PERALTA; and ) as Guardian of their minor children, ) L. PERALTA and S.M. PERALTA, ) ) Appellants, ) ) v. ) ) BRADLEY J. BLAKLEY, M.D., and ) JANE DOE BLAKLEY; EMERGENCY ) UNPUBLISHED OPINION ASSOCIATES OF YAKIMA, PLLC; ) YAKIMA VALLEY MEMORIAL ) HOSPITAL ASSOCIATION d/b/a ) VIRGINIA MASON MEMORIAL ) HOSPITAL, a/k/a YAKIMA VALLEY ) MEMORIAL, ) ) Respondents, ) ) JOHN DOES 1-10, ) ) Defendants. )

STAAB, J. — Miguel Peralta checked himself into the emergency department at

Yakima Valley Memorial Hospital (Hospital) for suicidal ideation. The emergency room

physician, Bradley Blakley, M.D., determined that Peralta did not have suicidal ideations No. 38616-3-III Peralta v. Blakley

and most likely did not meet the criteria for inpatient treatment. After discussing options,

Dr. Blakley discharged Peralta with information about mental health resources and

instructions to contact his primary care physician, follow up with a counselor, and return

to the emergency department if his symptoms worsened. The next day, Peralta died of

suicide.

Peralta’s family and estate (collectively the Estate) filed a medical negligence

action against the Hospital and Dr. Blakley (collectively Respondents). Through its

expert, the Estate alleged that Dr. Blakley’s evaluation of Peralta fell below the standard

of care. The Estate argued that the Respondents were negligent by not admitting or

detaining Peralta for inpatient treatment or providing an inadequate disposition-for-safety

plan upon his release. Following discovery, the trial court granted the Respondents’

motion for summary judgment, dismissing all of the Estate’s claims. After the Estate’s

motion for reconsideration was denied, the Estate filed this appeal.

We affirm the trial court’s order dismissing the Estate’s claim that the Respondents

should have voluntarily admitted or involuntarily detained Peralta because the Estate has

failed to produce evidence of gross negligence. However, the Estate’s claim that Dr.

Blakley’s disposition-for-safety plan was inadequate is subject to the ordinary medical

2 No. 38616-3-III Peralta v. Blakley

negligence standard.1 Since the Estate has provided evidence of each element of

negligence, the trial court erred in dismissing this claim on summary judgment.

BACKGROUND

Because this issue was decided in favor of the Respondents on summary judgment,

the following facts are set forth in a light most favorable to the Estate.

Miguel Peralta, accompanied by family members, voluntarily presented himself to

the Hospital’s emergency room with suicidal ideation. Peralta spoke with a triage nurse

who reported that he had increased stress, thoughts of harming himself for about a month,

and had been drinking heavily (although he was currently sober). The nurse also reported

that Peralta had a history of type 2 diabetes but had not been eating and may not have

been taking his medications properly. Peralta had no history of mental health issues.

Peralta next spoke with the primary emergency department nurse who recorded

that Peralta said he had been drinking too much (more than 10 drinks per day) and did not

have a plan to kill himself, although he had texted someone saying that he was at “the end

of [his] rope.” Clerk’s Papers at 83, 99. The nurse also conducted a standard suicide

screening questionnaire and notified the emergency department physician,

1 The “ordinary medical negligence standard” is referring to the standard of care outlined in chapter 7.70 RCW.

3 No. 38616-3-III Peralta v. Blakley

Dr. Blakley, of Peralta’s score.2

Dr. Blakley then evaluated Peralta. He recorded the following notes on Peralta:

45 YOM [year old male] presents for increased SI [suicidal ideation] since Sunday Upon examination Negative SI, no HI [homicidal ideation], alert and oriented x3 Advised that pt [patient] can be seen by MHP [mental health professional]. Advised of MHP process. Advised against calling MHP. Will provide contact for counselor so pt can set up follow up appointment. Pt agreed to follow up with counselor. Pt is cleared for discharge. Pt understands and agrees.

Id. at 101. Dr. Blakley advised Peralta against calling in a mental health professional to

the emergency department to see Peralta because he did not believe Peralta met the

inpatient criteria. Nonetheless, he indicated that Peralta could choose to be seen by a

mental health professional to determine whether inpatient services were necessary.

Peralta declined to do so and agreed to follow up with a counselor. A staff member at the

emergency department had ordered alcohol, drug, and metabolic tests for Peralta, but Dr.

Blakley subsequently canceled these tests.

Dr. Blakley sent Peralta home with a diagnosis of “‘acute stress reaction.’” Id.

(capitalization omitted). He directed Peralta to follow up with his primary care provider

2 Peralta’s score on this assessment was a 9, but the record does not provide any reference, so we do not assign any significance to this score.

4 No. 38616-3-III Peralta v. Blakley

in one to two days and return to the emergency room if his symptoms worsened. Peralta

was given a crisis hotline card, and he and his family were advised that they could call at

any time. Peralta was also provided with information for a counselor.

The next day, Peralta shot himself and died from his injuries.

Negligence Claim and Summary Judgment

Peralta’s wife, minor children, and Estate filed a lawsuit against Dr. Blakley and

the Hospital for medical negligence. Shortly thereafter, the Respondents moved for

summary judgment, arguing that the Estate had failed to identify an expert witness who

could testify to breach of care and proximate cause. The Respondents also argued that

medical decisions on whether to admit or detain Peralta for inpatient mental health

treatment were covered by the involuntary treatment act (ITA), chapter 71.05 RCW,

which required the Estate to prove gross negligence rather than ordinary medical

negligence.

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