Robinson, M. v. Mercy Fitzgerald Hospital

CourtSuperior Court of Pennsylvania
DecidedJuly 7, 2021
Docket3498 EDA 2019
StatusUnpublished

This text of Robinson, M. v. Mercy Fitzgerald Hospital (Robinson, M. v. Mercy Fitzgerald Hospital) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Robinson, M. v. Mercy Fitzgerald Hospital, (Pa. Ct. App. 2021).

Opinion

J-A19014-20

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT I.O.P. 65.37

MICHELLE ROBINSON : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : MERCY FITZGERALD HOSPITAL AND : TRINITY HEALTH : : No. 3498 EDA 2019 Appellants : : : : : v. : : : BIANCA GREEN : :

Appeal from the Order Entered October 21, 2019 In the Court of Common Pleas of Philadelphia County Civil Division at No(s): No. 170102249

BEFORE: PANELLA, P.J., McLAUGHLIN, J., and McCAFFERY, J.

MEMORANDUM BY PANELLA, P.J.: FILED JULY 07, 2021

This appeal stems from a premises liability cause of action, after the

appellee, Michelle Robinson, a wheelchair bound paraplegic, crashed onto the

pavement at a parking lot while exiting her minivan that was fitted with a

ramp. That parking lot was owned and managed by the appellants, Mercy

Fitzgerald Hospital and Trinity Health (collectively, “the Hospital”).1 As a result

____________________________________________

1 Mercy Fitzgerald Hospital is part of the Trinity Health system. See N.T., 5/21/2019, at 60. J-A19014-20

of the accident, Robinson broke her left tibia, suffered back pain and spasms,

facial abrasions, in addition to aggravating a degenerative disc disease and

lumbar stenosis. Robinson claimed the designated handicapped parking space

area at issue was situated on a significant slope to allow for water drainage

and therefore, created a dangerous condition for physically disabled

individuals, including those wheelchair bound, to enter and exit their vehicles.

The matter went to trial and the jury found in Robinson’s favor in the amount

of $473,888.76 for past and future economic losses and non-economic losses.

On appeal, the Hospital raises several evidentiary challenges and seeks

remittitur of damages. Based on the following, we affirm.

Robinson and her husband filed a complaint in January of 2017, and

then amended complaints in February and March of that year, that were

predicated on claims of negligence and premises liability. The Robinsons

asserted the Hospital was negligent in its operation and maintenance of the

parking areas on the hospital’s property, which therein caused dangerous and

unsafe conditions to exist. They specifically alleged that the parking spot at

issue “was situated on a substantial and severe slope and angle that was [a]

dangerous hazard and unsafe for physically disabled people including those

confined to wheelchairs to get into and/or out of vehicles in the designated

space without tipping over, falling and/or otherwise being injured.” Second

Amended Civil Action Complaint Premises Liability/General Negligence,

-2- J-A19014-20

3/16/2017, at ¶ 15.2 Bianca Green was joined as an additional defendant in

the matter.3 See Order, 3/12/2018. Pleadings and discovery were

subsequently exchanged.

In May 2019, the parties filed numerous motions in limine. The

Robinsons sought to preclude any reference or argument concerning the

alleged negligence of Green. The Hospital sought to preclude the Robinsons

from asserting any claims for economic damages related to past medical

expenses and future medical expenses, violations of ADA and comparable

Pennsylvania standards at the time of trial, and any reference to a heightened

duty of care owed by hospitals.

On May 21, 2019, the court entered a series of orders addressing the

parties’ motions in limine. The court denied the Robinsons’ motion regarding

Green’s negligence. The court granted the Hospital’s motion in limine

regarding a heightened duty of care and stated that the parties may reference

the duties a possessor of land owed to a business invitee. The court denied

the Hospital’s motion as to past medical expenses and future medical

expenses, stating the Robinsons’ complaint was a premises liability action and

the Hospital’s joinder and cross-claim was a motor vehicle responsibility

2 Robinson’s husband also brought forth a loss of consortium claim that was

subsequently withdrawn at trial prior to jury deliberations.

3 Green is not a party to this appeal.

-3- J-A19014-20

action. Lastly, the court denied the Hospital’s motion regarding the ADA and

similar Pennsylvania standards.

The case proceeded to a jury trial on May 20, 2019. At trial, the Hospital

did not dispute that Robinson suffered injuries due to the accident in the

parking lot. Nor did the Hospital present any expert evidence that the parking

spot where Robinson was injured was safe for wheelchair use. Instead, the

trial centered on two major factual disputes: (1) whether Robinson’s health

aid, Bianca Green, was negligent for parking where she did, and (2) whether

the future medical expenses claimed by Robinson are the result not of the

instant accident, but of injuries suffered by Robinson prior to this incident.

On May 28, 2019, the jury returned a verdict in favor of Robinson in the

amount of $473,888.76. The jury specifically allotted damages as follows: (1)

$23,888.76 for past medical expenses; (2) $100,000 for future medical

expenses; and (3) $350,000 for past, present, and future pain and suffering,

embarrassment and humiliation, and loss of enjoyment of life. The jury also

found the Hospital was 90% liable, Green was 7% liable, and Robinson was

3% comparatively negligent.4

4 The Hospital was deemed liable for the total amount of damages. Under the

Fair Share Act, 42 Pa.C.S.A. § 7102, joint and several liability was abolished in most tort cases. However, the statute provides for several exceptions to this general rule, including where the defendant has been held liable for not less than 60% of the total liability apportioned to all parties. See 42 Pa.C.S.A. § 7102(a.1)(3)(iii). Because the Hospital was found to be 90% liable, it was joint and severally liable for the whole amount.

-4- J-A19014-20

Robinson filed a post-trial motion to mold the verdict, alleging that

because the Hospital’s liability exceeded 60%, they were responsible for the

entire verdict amount pursuant to 42 Pa.C.S.A. § 7102. Robinson also filed a

post-trial motion for delay damages pursuant to Pa.R.C.P. 238. The Hospital

also filed a post-trial motion, seeking a new trial on liability and damages or,

in the alternative, granting a remittitur and reduction of the verdict.

On October 16, 2019, argument was held on the parties’ motions. Five

days later, the court entered an order denying the Hospital’s motion for post-

trial relief. That same day, the court entered a separate order granting

Robinson’s motions. The court then entered judgment in favor of Robinson

and against the Hospital in the amount of $495,136.06. This timely appeal

followed.5

The Hospital’s four issues on appeal all challenge the trial court’s denial

of post-trial relief. Our review of a trial court’s denial of a motion for post-trial

relief is limited to an abuse of discretion or error of law:

An abuse of discretion exists when the trial court has rendered a judgment that is manifestly unreasonable, arbitrary, or capricious, has failed to apply the law, or was motivated by partiality, prejudice, bias, or ill will. If the alleged mistake concerned an error of law, we will scrutinize for legal error. On questions of law, our standard of review is de novo and our scope of review is plenary.

5 On November 21, 2019, the trial court ordered the Hospital to file a concise

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