Rose Cottonaro v. Express Medical Transportation, INC.

CourtMissouri Court of Appeals
DecidedMarch 12, 2024
DocketWD86114
StatusPublished

This text of Rose Cottonaro v. Express Medical Transportation, INC. (Rose Cottonaro v. Express Medical Transportation, INC.) is published on Counsel Stack Legal Research, covering Missouri Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rose Cottonaro v. Express Medical Transportation, INC., (Mo. Ct. App. 2024).

Opinion

IN THE MISSOURI COURT OF APPEALS WESTERN DISTRICT ROSE COTTONARO, ) ) Respondent, ) v. ) WD86114 ) ) OPINION FILED: EXPRESS MEDICAL ) March 12, 2024 TRANSPORTATION, INC., ) ) Appellant. )

Appeal from the Circuit Court of Jackson County, Missouri The Honorable Charles H. McKenzie, Judge

Before Division Two: Anthony Rex Gabbert, Presiding Judge, and Karen King Mitchell and Janet Sutton, Judges

Express Medical Transportation, Inc. (Express) appeals from a judgment finding it

negligent and awarding Rose Cottonaro compensatory and punitive damages. Express

raises two points on appeal. First, Express asserts the trial court erred in admitting

evidence of three “other similar incidents” (OSIs) involving Express because those

incidents were not substantially similar to Cottonaro’s incident in that the OSIs involved

different drivers, vehicles, and specific means of alleged injury. Second, Express argues

the court erred in submitting Cottonaro’s claim for punitive damages to the jury because

that claim was based solely on the OSI evidence that was insufficient to support submission. Because Express failed to properly preserve its first point, and that point is

dispositive, we affirm the trial court’s judgment.

Background

Express provides non-emergency medical transportation for individuals who need

to be transported via wheelchair or stretcher. On July 5, 2019, Express transported

Cottonaro from her home in Harrisonville, Missouri, to Sarah Cannon Cancer Center at

Research Medical Center in Kansas City, Missouri. At the time, Cottonaro was

approximately 83 years old and used a wheelchair.

Approximately thirty minutes into the drive, Express’s van stopped at a red light

near the Cancer Center. When the light turned green and the van accelerated, Cottonaro’s

wheelchair moved backwards, and she hit her head. Express’s driver (Driver) took

Cottonaro to the emergency room, where she underwent a CT scan and was treated for a

cut on her leg. The results of the CT scan were normal, and the cut did not require

stitches. It took a couple of months for the “goose egg” on her head to resolve; she also

reported some neck and hip pain but did not seek additional medical treatment.

Cottonaro filed a petition against Express and Driver on December 23, 2019, and

an amended petition on July 24, 2020. The amended petition included claims for

negligence against Express and Driver and claims for negligent

hiring/supervision/direction and punitive damages against Express only. On Express’s

motion, the trial court issued an order bifurcating the trial as to Cottonaro’s claim for

punitive damages.

2 At trial, Express’s corporate designee (Designee) explained how Express’s drivers

are trained to secure wheelchairs for transport in its vans. Designee testified that each

van has four floor-mounted anchors or bolts, two in front and two in back. The driver

first engages the brakes on the wheelchair and then hooks each anchor to the wheelchair’s

frame—the right front anchor to the right front of the frame, the left front anchor to the

left front of the frame, the right rear anchor to the right rear of the frame, and the left rear

anchor to the left rear of the frame. The driver then tightens the restraints by pulling on

them to make sure they are tight. The only way to release the restraints is to push the red

release button. Then, the driver attaches and secures a safety belt around the passenger.

Once the wheelchair and the passenger are secured, the driver shakes the chair from

behind to make sure there is no more than two inches of movement in any direction.

Designee also testified about the training Driver received. According to Designee,

Express’s employee handbook specified that new drivers receive a minimum of two

weeks of on-the-job training, but the company’s practice was to provide between five and

ten days of initial training. In Driver’s case, she rode with a veteran driver for five days,

observing for the first three days and then, for the last two days, performing all tasks on

Express’s training checklist. Designee explained that Driver “would have got[ten]

intense training . . . on securing the wheelchair since that is the most important thing . . .

we do.”

According to Designee, following Driver’s five days of on-the-job training, Driver

performed a test run with an Express manager who observed as Driver again completed

the tasks on the training checklist. Designee then met with Driver for “hours” of “pretty

3 intense” training on a range of safety topics. The final step in the initial training process

involved Driver pushing Designee in a wheelchair, securing the wheelchair in the van,

and taking a test drive with Designee. Designee also testified that all Express drivers

attended bi-monthly training meetings on a variety of topics, including wheelchair

securement.

The trial court permitted Cottonaro’s counsel to introduce, through Designee’s

testimony, evidence of three OSIs all involving allegations of failure to properly secure a

passenger. 1 Express claimed all three of those passengers, like Cottonaro, were properly

secured by the drivers using the same restraint system and all the other drivers received

1 Before trial, Express filed motions in limine seeking to exclude evidence of five OSIs based on lack of substantial similarity between those incidents and the Cottonaro incident. After extensive argument, the trial court denied those motions as to the three OSIs at issue on appeal. However, the court explained that denying the motions

does not mean that I am, you know, determining the admissible element of evidence to get it in. And I don’t think I know enough about that necessarily, . . . there’s different ways to get in that type of evidence and I encourage you to be prepared to do it in a proper way. ... I find in an operative way only as a motion in limine that I’m going to deny it [as to the three OSIs at issue on appeal], as I stated. That doesn’t mean it’s just whatever way you want to put it in is admissible, you’re going to have to figure that out for yourself. And that evidence has to be otherwise admissible, one way or another. ... I mean, and that’s just also based upon the operative facts as presented. This ruling is interlocutory and could be reconsidered if I know more.

In its written order denying the motions in limine as to the three OSIs at issue, the court wrote, “[W]ith adequate foundation, Plaintiff, and her counsel, may question Defendants’ representatives about [the three OSIs] at trial. Specific objections to the admissibility of th[ose] incidents . . . will be addressed as they arise.”

4 the same securement training as Driver. Designee also testified that she really did not

receive complaints about passengers being improperly secured and injuries to Express’s

passengers are “very rare.”

Driver, who worked for Express for roughly eight months beginning in January

2019, testified that she rode with a veteran driver for a week and then with an Express

manager for a day. Driver also completed a CPR course. Driver confirmed that Express

offered safety reviews, but she did not mention a training session or a demonstration with

Designee.

As for the incident at issue, Driver testified that she wheeled Cottonaro, who was

traveling in her own wheelchair, up the ramp into the van, placed the wheelchair in

position, and locked the wheelchair’s wheels. 2 Next, Driver strapped the Q-Straints to

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Rose Cottonaro v. Express Medical Transportation, INC., Counsel Stack Legal Research, https://law.counselstack.com/opinion/rose-cottonaro-v-express-medical-transportation-inc-moctapp-2024.