Sarah Ann Richter & Tyson Richter v. Kevin Harrington, M.D.

CourtCourt of Appeals of Washington
DecidedMarch 10, 2020
Docket36259-1
StatusUnpublished

This text of Sarah Ann Richter & Tyson Richter v. Kevin Harrington, M.D. (Sarah Ann Richter & Tyson Richter v. Kevin Harrington, 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
Sarah Ann Richter & Tyson Richter v. Kevin Harrington, M.D., (Wash. Ct. App. 2020).

Opinion

FILED MARCH 10, 2020 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

C.R.,† a minor, By and Through His ) Natural Parents, SARAH ANN RICHTER ) No. 36259-1-III and TYSON RICHTER, and SARAH ) ANN RICHTER, Individually, and ) TYSON RICHTER, Individually, ) ) Appellants, ) UNPUBLISHED OPINION ) v. ) ) KEVIN HARRINGTON M.D.; ) GENERATIONS OB/GYN, PLLC, ) ) Respondents. )

KORSMO, J. — C.R. and his parents appeal from a jury verdict in favor of Dr.

Kevin Harrington and rejecting their medical malpractice claims arising from C.R.’s

birth. They argue that the trial court improperly allowed a biased juror to sit and

permitted an unqualified expert to testify at trial. Concluding that the trial court did not

abuse its discretion, we affirm.

† To protect the privacy interests of C.R., a minor, we use his/her initials throughout this opinion. No. 36259-1-III Richter, et al v. Harrington, M.D., et al

FACTS

Dr. Harrington delivered C.R. During the birth process, C.R. shifted in the birth

canal and Dr. Harrington used the McRoberts’ position to deliver the child. C.R. was

born with a brachial plexus nerve injury that impacts the left arm. The family claimed

that the injury resulted from an improper procedure during delivery.

During jury selection, the plaintiffs sought to exclude for cause all prospective

jurors who had a child delivered by Dr. Harrington. Juror 25 had one of his children

delivered by Dr. Harrington 14 years earlier; he explained to the court why he could be

impartial. The court declined to excuse juror 25 for cause and juror 25 eventually served

on the jury. Others in the jury pool who had children delivered by Dr. Harrington were

excluded for cause, including one whose child was delivered four years earlier and

another who was receiving ongoing care from Dr. Harrington.

At trial, the defense introduced testimony from Dr. Mark Scher, a pediatric

neurologist, whose testimony explained the cause of brachial plexus and the prognosis for

the child. The family objected to any testimony by Dr. Scher concerning the childbirth

process because he was not an obstetrics specialist. Dr. Scher testified he regularly

worked with obstetricians to assist children with brachial plexus injuries before and after

birth, including fetuses at risk for brachial plexus injuries. He has to understand the

impact of birth on the nervous system as part of his neurology specialty. Dr. Scher also

studied childbirth as part of his medical school training and assisted another doctor in a

2 No. 36259-1-III Richter, et al v. Harrington, M.D., et al

published work on brachial plexus injuries. The court allowed the doctor to testify about

childbirth after finding Dr. Scher had sufficient experience with brachial plexus injuries

to explain causation.

The jury returned in favor of Dr. Harrington by a 10-2 jury verdict. The family

appealed to this court. A panel considered this case without hearing argument.

ANALYSIS

Jury Selection

The family contends that the court erred in refusing to exclude juror 25 for cause.

The court did not abuse its discretion.

The trial court possesses discretion when granting or denying a challenge for

cause; a reviewing court will reverse the trial court only for manifest abuse of discretion.

State v. Gilcrist, 91 Wn.2d 603, 611, 590 P.2d 809 (1979). A trial court abuses its

discretion if its decision is manifestly unreasonable, or is exercised on untenable grounds,

or for untenable reasons. State ex rel. Carroll v. Junker, 79 Wn.2d 12, 26, 482 P.2d 775

(1971). This standard of review recognizes that the trial court holds the best position to

determine whether a juror can be fair and impartial because the trial court observes the

juror’s demeanor and evaluates the juror’s answers. State v. Birch, 151 Wn. App. 504,

512, 213 P.3d 63 (2009).

Our statutes do not imply bias from the existence of a doctor-patient relationship.

A party must, therefore, establish a juror’s actual bias. Family Med. Bldg., Inc. v. Dep’t

3 No. 36259-1-III Richter, et al v. Harrington, M.D., et al

of Soc. & Health Servs., 37 Wn. App. 662, 675-676, 684 P.2d 77 (1984). Actual bias is

defined as “the existence of a state of mind on the part of the juror in reference to the

action, or to either party, which satisfies the court that the challenged person cannot try

the issue impartially and without prejudice to the substantial rights of the party

challenging.” RCW 4.44.170(2).

When a party challenges a prospective juror for cause, the trial court must

determine whether the juror can set aside preconceived ideas and try the case fairly and

impartially. Hough v. Stockbridge, 152 Wn. App. 328, 341, 216 P.3d 1077 (2009). A

prior or ongoing business relationship involving a party and a juror may suggest actual

bias, but the trial court must examine the relevant circumstances and the juror’s

demeanor. Ottis v. Stevenson-Carson Sch. Dist. No. 33, 61 Wn. App. 747, 755-757, 812

P.2d 133 (1991).

The trial court judge allowed each party to question each juror about prior

relationships with Dr. Harrington and the judge provided reasoned decisions on the

record concerning each challenge for cause. The judge excused those who had recent or

ongoing relationships with Dr. Harrington or expressed apparent favoritism to the doctor.

The trial court found that juror 25 had a remote relationship with Dr. Harrington and

could remain impartial. Those were tenable grounds for declining to excuse juror 25.

There was no abuse of discretion.

4 No. 36259-1-III Richter, et al v. Harrington, M.D., et al

Expert Testimony

Appellants also challenge the decision to permit Dr. Scher to testify concerning

the birth process, arguing both that he was unqualified and was an improper extra expert

witness. Once again, the trial judge did not abuse his discretion.

Washington uses the Frye1 test to limit expert testimony to principles generally

accepted in the scientific community. State v. Canaday, 90 Wn.2d 808, 812, 585 P.2d

1185 (1978). If the scientific principle satisfies Frye, the trial court applies ER 702 in

determining whether to admit the individual expert’s testimony. In re Det. of Pettis, 188

Wn. App. 198, 205, 352 P.3d 841 (2015). This court reviews the trial court’s decision to

admit an expert witness for abuse of discretion. Id. A witness may qualify as an expert

by knowledge, skill, experience, training, or education. ER 702. After an expert’s

qualifications are established, any deficiencies in the expert’s knowledge goes to the

evidentiary weight of the testimony. Keegan v. Grant County Pub. Util. Dist. No. 2, 34

Wn. App.

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Related

State Ex Rel. Carroll v. Junker
482 P.2d 775 (Washington Supreme Court, 1971)
State v. Gilcrist
590 P.2d 809 (Washington Supreme Court, 1979)
Keegan v. Grant County Public Utility District No. 2
661 P.2d 146 (Court of Appeals of Washington, 1983)
State v. Rangitsch
700 P.2d 382 (Court of Appeals of Washington, 1985)
Ottis v. Stevenson-Carson School District No. 303
812 P.2d 133 (Court of Appeals of Washington, 1991)
Family Medical Building, Inc. v. Department of Social & Health Services
684 P.2d 77 (Court of Appeals of Washington, 1984)
State v. Birch
213 P.3d 63 (Court of Appeals of Washington, 2009)
Hough v. Stockbridge
216 P.3d 1077 (Court of Appeals of Washington, 2009)
State v. Canaday
585 P.2d 1185 (Washington Supreme Court, 1978)
L.M. by and Through Dussault v. Hamilton
436 P.3d 803 (Washington Supreme Court, 2019)
State v. Birch
151 Wash. App. 504 (Court of Appeals of Washington, 2009)
Hough v. Stockbridge
152 Wash. App. 328 (Court of Appeals of Washington, 2009)
In re the Detention of Pettis
352 P.3d 841 (Court of Appeals of Washington, 2015)
Frye v. United States
293 F. 1013 (D.C. Circuit, 1923)

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