Shirley Langley, Et Ux. v. American Legion Hospital

CourtLouisiana Court of Appeal
DecidedMay 2, 2012
DocketCA-0011-1521
StatusUnknown

This text of Shirley Langley, Et Ux. v. American Legion Hospital (Shirley Langley, Et Ux. v. American Legion Hospital) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Shirley Langley, Et Ux. v. American Legion Hospital, (La. Ct. App. 2012).

Opinion

NOT DESIGNATED FOR PUBLICATION

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

11-1521

SHIRLEY LANGLEY, ET UX.

VERSUS

AMERICAN LEGION HOSPITAL

**********

APPEAL FROM THE FIFTEENTH JUDICIAL DISTRICT COURT PARISH OF ACADIA, NO. 209-10573 HONORABLE DURWOOD WAYNE CONQUE, DISTRICT JUDGE

ELIZABETH A. PICKETT JUDGE

Court composed of Ulysses Gene Thibodeaux, Chief Judge, Sylvia R. Cooks, and Elizabeth A. Pickett, Judges.

AFFIRMED AS AMENED.

Nicholas J. Sigur Attorney at Law Post Office Box 81834 Lafayette, Louisiana LA 70598 (337) 205-2353 Counsel for Defendant/Appellant: American Legion Hospital Benjamin P. Mouton Eric E. Helm McGlynn, Glisson & Koch Post Office Box 1909 Baton Rouge, Louisiana 70821 (225) 344-3555 Counsel for Plaintiffs/Appellants: Shirley Langley Gregory Langley PICKETT, Judge.

Husband and wife sued hospital for damages they claim to have suffered as a

result of the wife’s having been administered epinephrine intravenously rather than

subcutaneously. For the following reasons, we amend and affirm the judgment of the

trial court.

FACTS

On December 5, 2007, Shirley Langley sought treatment in the emergency

room (ER) at the American Legion Hospital (the hospital) in Crowley after

experiencing an allergic reaction to a bee sting. The initial treatment of epinephrine

injected subcutaneously, as ordered by the ER physician, was successful, but

Mrs. Langley developed a rebound reaction to the bee sting. To address the rebound

reaction, the ER physician ordered that a second dose of epinephrine be administered

subcutaneously, but it was administered intravenously.

The hospital’s records show that immediately after the intravenous

administration of the epinephrine, Mrs. Langley complained of pain in her head. Her

heart rate increased from 101 beats per minute to 180-190 beats per minute, and her

blood pressure rose from 136/55 to 205/129. Her reaction was diagnosed as sudden

onset of supraventricular tachycardia, which is a regular fast heart beat caused by

rapid firing of electrical impulses that originate above the heart’s ventricles. 1 This

reaction required the ER physician to perform “vagal massage,” i.e., massage of the

carotid artery in Mrs. Langley’s neck. 2 The episode associated with the intravenous

administration of the epinephrine lasted approximately one minute. Mrs. Langley was

then admitted to the Intensive Care Unit with a diagnosis of allergic reaction to bee

1 As defined in “Supraventricular Tachycardia–Topic Overview,” MedicineNet.com, August 9, 2010, http://www.MedicineNet.com/ heart-disease. 2 This explanation is garnered from the ER physician’s history because a definition for the term “vagal massage” could not be found. See also, “Vagal Maneuvers for A Fast Heart Rate,” WebMD.com, August 9, 2010, http://www.WebMD.com/a-to-z-guides. sting and supraventricular tachydardia secondary to epinephrine. She was treated and

monitored for approximately eight hours before being discharged.

Mrs. Langley and her husband Gregory sued the hospital for damages they

claim to have suffered as a result of the episode. They claim the evidence introduced

at trial shows this medication error caused measurable, permanent damage to

Mrs. Langley’s heart and permanent damage to the “peripheral nerves in her upper

and lower extremities, resulting in pain and loss of sensation.” They further claim the

error caused Mrs. Langley to experience nightmares, intrusive memories, anxiety,

panic attacks, sleep deprivation, weight loss, and bouts of sadness/tearfulness which

she will likely continue to experience. They also assert Mr. Langley has suffered a

loss of consortium with Mrs. Langley as a result of the episode.

At trial, the parties stipulated that the nurse’s administration of the epinephrine

intravenously, rather than subcutaneously as ordered, constituted a breach of the

standard of care by the hospital. Therefore, the parties addressed only the issues of

causation and damages at trial.

Mrs. Langley testified the episode caused her to suffer the worst pain she had

ever suffered. Additionally, she testified she saw bugs crawling everywhere; she

ground her teeth; her stomach hurt badly; her chest felt tight and painful; she felt as if

she were constantly gasping for breath; and she felt anxious and agitated. Thereafter,

Mrs. Langley sought treatment for pain and numbness in her extremities, anxiousness,

nightmares, and other mental/emotional complaints. She was diagnosed with having

five percent damage to her heart. Mr. and Mrs. Langley also testified that the effects

of the episode on Mrs. Langley impacted their relationship with each other.

At the conclusion of the trial, the trial court took the matter under advisement

and subsequently issued Reasons for Judgment in which it awarded Mrs. Langley

2 $25,000 in general damages3 but denied Mr. Langley’s claim for loss of consortium.

Thereafter, the trial court signed a written judgment in accordance with its Reasons

for Judgment. The Langleys and the hospital appealed the judgment.

ASSIGMENTS OF ERROR

In their appeal, the Langleys assign two errors in the trial court’s judgment:

(1) The trial court committed a legal error or, in the alternative, committed manifest error when it failed to award Gregory Langley damages for his loss of consortium, given that the following three requirements were met: (a) the parties stipulated that the defendant breached the standard of care, (b) the trial court confirmed that Shirley was injured by the breach through its award of general damages, and (c) both Gregory and Shirley’s testimonies relevant to his loss of consortium claim were uncontested.

(2) The trial court’s award of $25,000 to Shirley Langley was abusively low considering the severity of her physical and emotional injuries and the higher awards given in similar cases for similar injuries.

The hospital assigns one error:

(1) The trial court erred in awarding damages to Mrs. Langley in that there was no evidence that any act of the hospital caused damage to her.

DISCUSSION

Proof of Causation

In its assignment of error, the hospital contends no evidence established the

episode caused Mrs. Langley’s reaction and argues the reaction Mrs. Langley suffered

may have been caused by the epinephrine itself.

The Langleys had to prove by a preponderance of the evidence that the

intravenous administration of the epinephrine caused Mrs. Langley’s injuries and

damages. Clark v. Parker, 08-941 (La.App. 3 Cir. 2/4/09), 2 So.3d 1262, writ denied,

09-401 (La. 4/13/09), 5 So.3d 165. “Proof is sufficient to constitute a preponderance

when the entirety of the evidence, both direct and circumstantial, shows the fact

sought to be proved is more probable than not.” Hebert v. Rapides Parish Police

3 The Langleys did not introduce evidence regarding their medical expenses; therefore, no award was made for those expenses. 3 Jury, 06-2001, 06-2164, p. 7 (La. 4/11/07), 974 So.2d 635, 642. We cannot reverse

the trial court’s determination that the Langleys met their burden of proof unless we

find its factual findings are manifestly erroneous. Miller v. PNK, 11-216 (La.App. 3

Cir. 10/5/11), 76 So.3d 122.

In its Reasons for Ruling, the trial court determined:

The defendant hospital is responsible only for those damages which are directly attributable to [its] breach of the standard of care required by the law of medical malpractice.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Bellard v. South Cent. Bell Telephone Co.
702 So. 2d 695 (Louisiana Court of Appeal, 1997)
Guillory v. Lee
16 So. 3d 1104 (Supreme Court of Louisiana, 2009)
Clark v. Parker
2 So. 3d 1262 (Louisiana Court of Appeal, 2009)
Youn v. Maritime Overseas Corp.
623 So. 2d 1257 (Supreme Court of Louisiana, 1993)
Wainwright v. Fontenot
774 So. 2d 70 (Supreme Court of Louisiana, 2000)
Hebert v. Rapides Parish Police Jury
974 So. 2d 635 (Supreme Court of Louisiana, 2008)
Miller v. PNK
76 So. 3d 122 (Louisiana Court of Appeal, 2011)
Hardy v. Augustine
55 So. 3d 1019 (Louisiana Court of Appeal, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
Shirley Langley, Et Ux. v. American Legion Hospital, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shirley-langley-et-ux-v-american-legion-hospital-lactapp-2012.