SW v. The United States of America U.S. Department of Justice

CourtDistrict Court, N.D. Ohio
DecidedMarch 10, 2021
Docket1:19-cv-02947
StatusUnknown

This text of SW v. The United States of America U.S. Department of Justice (SW v. The United States of America U.S. Department of Justice) is published on Counsel Stack Legal Research, covering District Court, N.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
SW v. The United States of America U.S. Department of Justice, (N.D. Ohio 2021).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO ------------------------------------------------------------------ S.W., : LYNDSEY WOJCEHOWICZ : , : : Case No. 1:19-cv-2947 Plaintiffs, : vs. : OPINION & ORDER : : [Resolving Docs. 69, 70, 71, 74] United States of America, , : : Defendants. : ------------------------------------------------------------------ JAMES S. GWIN, UNITED STATES DISTRICT JUDGE:

In this Federal Tort Claims Act medical malpractice case, Defendant United States of America sought the depositions of three physicians—Drs. Lenora Lehwald, Jonathan Pindrik, and Laurel Slaughter—who treated Plaintiff S.W. after his December 23, 2015 birth. The three physicians, through counsel, each refused to be deposed voluntarily, and the United States subpoenaed them to give testimony.1 The three physicians, joined by Plaintiffs, now move to quash each of the subpoenas.2 The government opposes,3 and the physicians reply.4 For the reasons stated below, the Court DENIES Drs. Slaughter and Pindrik’s quash motions and GRANTS Dr. Lehwald’s quash motion. I. DISCUSSION Generally, parties may obtain discovery regarding any matter not privileged that is relevant to the subject matter involved in the pending action.5 And parties may issue

1 Doc. 69-1; Doc. 70-1; Doc. 71-1 (Lehwald, Pindrik, and Slaughter subpoenas, respectively). 2 Doc. 69; Doc. 70; Doc. 71; Doc. 74. 3 Doc. 73. 4 Doc. 77. 5 Fed. R. Civ. Pro. 26(b)(1). subpoenas to compel non-parties to give testimony or produce documents.6 A subpoena must be quashed or modified, however, when it: “(i) fails to allow a reasonable time to comply; (ii) requires a person to comply beyond the geographical limits specified in [Federal

Rule of Civil Procedure] 45(c); (iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or (iv) subjects a person to undue burden.”7

The physicians first argue that the United States’ subpoenas are procedurally deficient on two grounds, requiring them to be quashed. First, the physicians claim that the United States did not pay the required fees and mileage sums to the physicians under Federal Rule of Civil Procedure 45(b)(1). But as the United States points out, the very same rule provides

that “[f]ees and mileage need not be tendered when the subpoena issues on behalf of the United States or any of its officers or agencies.”8 Second, the physicians argue that the subpoenas failed to specify a deposition recording method as required under Federal Rule of Civil Procedure 45(a)(1)(B). But, as the parties seem to acknowledge, this defect was cured by a subsequent subpoena, and, at any rate, failure to provide a recording method is not one of provided reasons requiring courts to quash or modify a subpoena.9

6 Fed. R. Civ. Pro. 45. 7 Fed. R. Civ. Pro. 45(d)(3)(A). 8 Fed. R. Civ. Pro. 45(b)(1). 9 , No. 12-cv-767, 2013 WL 12415761, at *3 n.2 (S.D. Cal. Feb. 7, 2013). Next, the physicians argue that the subpoenas improperly ask them to give expert testimony without submitting an expert report. The physicians have not been retained by either party for the purpose of providing expert testimony. Yet the United States believes

that the physicians may have formed opinions regarding the cause of Plaintiff S.W.’s injury while treating S.W. The physicians, joined by Plaintiffs, argue that such causation testimony would be improper absent a written expert report from the physicians, as required by Federal Rule of Civil Procedure 26(a)(2)(B). The United States disagrees. Addressing this precise issue, the Sixth Circuit has stated that treating physicians may offer expert opinions, including on causation issues, without offering a written expert report, so long as reaching such an opinion was “within the normal range of duties for a health care

provider to develop opinions regarding causation and prognosis during the ordinary course of an examination.”10 “[A] medical doctor is generally competent to testify regarding matters within his or her own professional experience,”11 and so long as a treating physician did not first form a medical opinion in anticipation of litigation, the treating physician may offer the opinion without necessarily providing a Rule 26(a)(2)(B) report.12

Each of the subpoenaed physicians personally treated S.W. before the present suit was filed, and each of them may have formed a causation opinion about S.W.’s injury, especially Dr. Slaughter, a pediatric neurologist who, as alleged in the complaint, first

10 , 482 F.3d 866, 869–70 (6th Cir. 2007). 11 , 558 F.3d 419, 427–28 (6th Cir. 2009). 12 , 482 F.3d at 871 (citing , 138 F. App’x 804, 811 (6th Cir. 2005)). diagnosed S.W. with cerebral palsy.13 Dr. Slaughter also communicated to S.W.’s parents that S.W.’s injury might have resulted from medical negligence.14 And while Dr. Lehwald and Dr. Pindrik may have been less involved in the discovery of S.W.’s claim, they were a

pediatric neurologist15 and a pediatric neurosurgeon16 who may have brain injury causation conclusions reached while treating S.W. Therefore, under , each subpoenaed physician may testify about an expert causation opinion they reached regarding S.W.’s injury in the ordinary course of treating S.W. Further, each physician might have relevant fact testimony regarding what communications, if any, they had with S.W.’s parents about the cause of S.W.’s injury. The United States’ physician subpoenas therefore seek proper testimony.

Crucially, however, does not apply to standard of care testimony, as forming a standard of care opinion is not part of the ordinary course of treatment. Accordingly, the physicians would be required to submit an expert report under Rule 26(a)(2)(B) before offering testimony on the applicable standard of care. The Court earlier established expert witness disclosure dates. The United States did not identify or provide a report for any of the physicians. Therefore, the United States cannot use the physician’s testimony on standard of care issues.17

13 Doc. 31 at 12–13. 14 15 Doc. 69 at 6. 16 Doc. 70 at 3. 17 Fed R. Civ. Pro. 37(c)(1). The physicians alternatively argue that even if they need not provide Rule 26(a)(2)(B) reports prior to giving expert causation testimony, that testimony still requires a Rule 26(a)(2)(C) opinion summary. Under Rule 26(a)(2)(C), even if Defendant United States is

excused from providing an expert report for the physicians, the United States must nonetheless disclose: “the subject matter on which [each] witness is expected to present evidence under Federal Rule of Evidence 702, 703, or 705; and a summary of the facts and opinions to which [each] witness is expected to testify.” For Rule 26(a)(2)(C) purposes, mere reference to unspecified testimony is insufficient.18 “Although the information required under Fed. R. Civ. P. 26(a)(2)(C) is less extensive than an expert report under 26(a)(2)(B) . . . the two forms of disclosure share the

goal of increasing efficiency and reducing unfair surprise.”19 To that end, the United States must give a detailed summary of the opinions the physicians might testify to at trial.

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

Related

Jesse A. Fielden v. Csx Transportation, Inc.
482 F.3d 866 (Sixth Circuit, 2007)
Gass v. Marriott Hotel Services, Inc.
558 F.3d 419 (Sixth Circuit, 2009)
Mohney v. USA Hockey, Inc.
138 F. App'x 804 (Sixth Circuit, 2005)
Ingram v. Novartis Pharmaceuticals Corp.
282 F.R.D. 563 (W.D. Oklahoma, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
SW v. The United States of America U.S. Department of Justice, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sw-v-the-united-states-of-america-us-department-of-justice-ohnd-2021.