State of Iowa v. Michael Buman

CourtCourt of Appeals of Iowa
DecidedJuly 1, 2020
Docket19-0981
StatusPublished

This text of State of Iowa v. Michael Buman (State of Iowa v. Michael Buman) is published on Counsel Stack Legal Research, covering Court of Appeals of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Iowa v. Michael Buman, (iowactapp 2020).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 19-0981 Filed July 1, 2020

STATE OF IOWA, Plaintiff-Appellee,

vs.

MICHAEL BUMAN, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Plymouth County, Steven J.

Andreasen, Judge.

Michael Buman appeals his conviction of wanton neglect of a resident in a

health care facility. CONVICTION REVERSED AND REMANDED.

Priscilla E. Forsyth, Sioux City, for appellant.

Thomas J. Miller, Attorney General, and Linda J. Hines, Assistant Attorney

General, for appellee.

Considered by Vaitheswaran, P.J., and Doyle and May, JJ. 2

DOYLE, Judge.

Michael Buman appeals his conviction of wanton neglect of a resident in a

health care facility, which stems from October 2016 events at the residential care

facility where Buman worked as a registered nurse. The State alleged that Buman

discontinued a resident’s antipsychotic medication without a doctor’s authorization,

which caused the resident to have a psychotic episode and require hospitalization.

Buman admits he noted the resident’s medication had been discontinued on the

medication administration record (MAR). But he claims that the facts available to

him at the time led him to conclude the resident’s medication had been

discontinued and he was only trying to correct an apparent clerical error.

On appeal, Buman challenges the evidentiary ruling allowing the State to

introduce the standard of care for registered nurses into evidence and the jury

instruction that addressed that evidence. He also challenges the sufficiency of the

evidence supporting the finding that he knowingly acted in a way that would likely

injure the resident.

I. Background Facts and Proceedings.

In October 2016, Buman was a nurse employed at a health care facility in

Le Mars. He worked what is called the night shift, starting at 6 p.m. and finishing

at 6 a.m. At around 8 p.m. on October 18, 2016, Buman was administering

medication when one of the facility’s residents asked Buman about his clozapine

prescription. According to Buman, the resident asked “why he wasn’t getting it

anymore because he had not had it for a quantity of days.” After checking the

medications he was dispensing, Buman verified that clozapine was not included

and told the resident he would look into it. 3

The MAR shows the resident’s clozapine had not been administered at least

two of the three days before Buman’s October 18 shift. Jane Ream, a registered

nurse with over forty years of experience, dispensed the resident’s medications

during the night shift on October 15 and 16. When Ream discovered that the

resident’s clozapine had not been included in the two-week supply of medication

the pharmacy had delivered on October 13, she marked “NA,” meaning “not

available,” next to clozapine on the MAR for October 15. Following the facility’s

policy, Ream informed the nurse on the day shift that the resident’s clozapine was

missing and that she would need to contact the pharmacy. But when Ream began

her shift the next night, the clozapine was still missing. Ream again marked it as

“NA” on the MAR for October 16. At the shift change, she alerted the nurse that

the clozapine was missing.

On October 17, a certified medication aide dispensed the resident’s

medications. The aide initialed that date on the MAR to show he had given the

resident clozapine along with his other medications. But, like Ream, Buman could

not find clozapine when he searched on October 18. Buman testified that after

talking to the resident, he did the following to satisfy himself that the clozapine was

not present:

I went back. I looked in the bin immediately. There was no cassette there. I eventually, that evening, went through both med carts, every single cassette in every bin, in every drawer, confirmed that it was not misplaced from there, that it was not in the cupboard, in the pharmacy return bags, or was not located anywhere else in the nurse’s station, period.

Buman believed that it had also been missing on October 17 and the aide had

been on “automatic mode and went down the page and made the initials in the 4

appropriate spots” rather than independently verifying each of the medications was

present.1

Based on the MAR and the resident’s statement that he had not been given

clozapine in several days, Buman concluded that it “had been discontinued or

otherwise changed to something else and that [someone] had failed to make that

notation in the MAR.” Buman sought to correct what he believed to be a clerical

error by writing “DC’ed,” meaning “discontinued,” under the entry for clozapine on

the MAR.

Buman testified that he “checked every record that was available to [him],

including the electronic records and did not find the medication listed recently.” He

admitted he did not check the resident’s medical chart because it had been

unavailable for some time before October 18 and was not present on that date as

well. Although the residents’ medical charts were typically kept in the nurse’s

station, both Buman and Ream testified that the charts were often locked in the

director of nursing’s office during the night shift and could not be accessed. The

facility did not keep a log book of change orders. Buman testified it was not

protocol to contact the director of nursing about a missing medication and the

pharmacy was unavailable to contact overnight.

On October 27, the resident was hospitalized after experiencing a psychotic

episode. Hospital notes state that the resident experienced “worsening psychotic

illness because his clozapine was inadvertently stopped on 10/18/2016.” On the

1 According to Buman, the staff provided the medications to each resident in a cup to take all together and, afterward, marked each off on the MAR rather than marking the MAR for each medication after distributing them individually. 5

incident report form completed by the facility’s administrator, the event was

categorized as a “minor incident” resulting from a “[p]rescription medication error.”

The report states the facility acted to provide immediate training to all medication

passers and implemented a new process to ensure medication was not

discontinued without a doctor’s order.

No further action was taken until January 2018, when the State began

investigating the facility for reasons unrelated to Buman. During that investigation,

Ryan Dostal, a State investigator, learned from other employees that Buman “on

his own and without doctor authorization” had discontinued the antipsychotic

medication in October 2016. After interviewing Buman, Dostal determined there

was probable cause to charge him with wanton neglect of a resident of a health

care facility.

The State filed felony criminal charges against Buman in July 2018.2 The

matter was tried to a jury in April 2019. In her testimony, the facility administrator

refuted Buman’s claim that the medication was missing on October 18. She

disagreed that the medical aide who initialed the MAR on October 17 could have

made a mistake in doing so. Although she admitted that she was not involved in

the medication delivery and did not contact the pharmacy herself, she viewed the

medical aide’s initials on the MAR as proof that the pharmacy delivered clozapine

after Ream’s October 16 shift.

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