San Jacinto Methodist Hospital and New Triumph Healthcare of Texas, LLC D/B/A Triumph Hospital East Houston v. Eric Bennett, Individually and as Representative of the Estate of Mary Jane Taylor

CourtCourt of Appeals of Texas
DecidedMay 29, 2008
Docket14-07-00639-CV
StatusPublished

This text of San Jacinto Methodist Hospital and New Triumph Healthcare of Texas, LLC D/B/A Triumph Hospital East Houston v. Eric Bennett, Individually and as Representative of the Estate of Mary Jane Taylor (San Jacinto Methodist Hospital and New Triumph Healthcare of Texas, LLC D/B/A Triumph Hospital East Houston v. Eric Bennett, Individually and as Representative of the Estate of Mary Jane Taylor) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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San Jacinto Methodist Hospital and New Triumph Healthcare of Texas, LLC D/B/A Triumph Hospital East Houston v. Eric Bennett, Individually and as Representative of the Estate of Mary Jane Taylor, (Tex. Ct. App. 2008).

Opinion

Affirmed and Opinion filed May 29, 2008

Affirmed and Opinion filed May 29, 2008.

In The

Fourteenth Court of Appeals

____________

NO. 14-07-00639-CV

SAN JACINTO METHODIST HOSPITAL AND NEW TRIUMPH HEALTHCARE OF TEXAS, LLC, D/B/A/ TRIUMPH HOSPITAL EAST HOUSTON, Appellants

V.

ERIC BENNETT, INDIVIDUALLY AND AS REPRESENTATIVE OF THE ESTATE OF MARY JANE TAYLOR DECEASED, Appellee

On Appeal from the 165th District Court

Harris County, Texas

Trial Court Cause No. 06-77425

O P I N I O N


In this interlocutory appeal in a health-care-liability case, two hospitals challenge the trial court=s denial of their respective objections to the plaintiff=s expert witness report and motions to dismiss under Texas Civil Practice and Remedies Code section 74.351.  We conclude the trial court reasonably could have determined that the plaintiff=s expert report was sufficient to meet the relevant requirements of the statute in relation to all claims the plaintiff was asserting at the time of the trial court=s orders.  We therefore hold the trial court did not abuse its discretion in denying the hospitals= objections and motions to dismiss.

I.  Factual and Procedural Background

Appellee Eric Bennett, individually and as representative of the estate of his mother, Mary Jane Taylor, filed a medical health care liability claim against appellants San Jacinto Methodist Hospital (AMethodist@) and New Triumph Healthcare of Texas, LLC, d/b/a/ Triumph Hospital East Houston (ATriumph@).  Bennett sought recovery under the Texas wrongful death and survival statutes[1] for injury and death allegedly resulting from Methodist=s and Triumph=s negligent diagnosis and treatment of his mother=s dicubitus ulcer, commonly known as a Abed sore.@

Bennett=s petition contains the following allegations:

!       On September 24, 2004, Taylor arrived at Methodist with breathing problems, and she was admitted to Methodist. 

!       During her stay at Methodist, she began to develop a bed sore.  On November 15, 2004, Taylor was transferred to Triumph for management of respiratory failure. 

!       During her stay at Triumph, Taylor=s bed sore progressed to stage four, penetrating to the bone. 

!       On November 30, 2004, Taylor returned to Methodist, and on January 11, 2005, she was transferred to Select Speciality Hospital, where she underwent skin grafts and a skin flap. 

!       Taylor remained hospitalized until October 27, 2005, when she died.


On April 9, 2007, Bennett timely filed a report by Dr. Timothy Hammond, Aan academic internist and nephrologist.@[2]  Dr. Hammond stated he was Aboard certified in internal medicine and this certification is valid indefinitely.  I was board certified in nephrology from 1996 to 2006 and am currently in the process of renewal.  These certifications directly address the subject matter of this claim, as the claim relates to management of decubitus ulcers.@  Dr. Hammond also stated he was practicing medicine at all times relevant to the claims made in the case and was actively practicing at the time of his opinion.  He continued, stating:

I have either has [sic] training as, and/or served as a consultant, and/or observed healthcare providers in the same fields as the defendant healthcare providers named in the Taylor case.  Therefore, I have knowledge of accepted standards of medical care for the diagnosis, care, or treatment of the illness, injury, or condition involved in the claim, as the claim relates to the prevention and management of decubitus ulcers.  I am familiar with the standard of care for both nurses and physicians for the prevention and treatment of decubitus ulcers.  I give direct care to patients with decubitus ulcers and was doing so at all times relevant to this case.  As such, I am also familiar with the consequences of improper management of decubitus ulcers that is not within the standard of care.

After listing the records he reviewed and summarizing the details of Taylor=s clinical  and medical history, Dr. Hammond opined that the following evidence supported the claim that Taylor=s skin integrity was breached during her first stay at Methodist:  (1) a January 12, 2005 wound care progress note from Select Speciality Hospital indicating the Asacral decubiti are 22 months old,@ and (2) inclusion of an order for Duoderm to the sacrum in the November 15, 2004 transfer orders to Triumph.  Dr. Hammond also opined that Taylor=s laboratory results from Methodist were Aconsistent with prolonged dehydration and malnutrition as evidence[d] by BUN/Creatinine rations [sic] >20 (Ratio) and low albumin and pre-albumin levels . . . .@  He then provided the supporting tabulations.


Regarding Taylor=s stay at Triumph, Dr. Hammond reported, among other matters, that Taylor Adeveloped Pseudomonas bacteremia, and had ongoing malnutrition.@[3]  He further observed that a sacral decubitus was noted in the hospital discharge summary, but no skin care documentation was included in this record.  He provided the pre-albumin levels in Taylor=

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San Jacinto Methodist Hospital and New Triumph Healthcare of Texas, LLC D/B/A Triumph Hospital East Houston v. Eric Bennett, Individually and as Representative of the Estate of Mary Jane Taylor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/san-jacinto-methodist-hospital-and-new-triumph-healthcare-of-texas-llc-texapp-2008.