Tahboub v. Thiagarajah

CourtSupreme Court of Virginia
DecidedFebruary 13, 2020
Docket190019
StatusPublished

This text of Tahboub v. Thiagarajah (Tahboub v. Thiagarajah) is published on Counsel Stack Legal Research, covering Supreme Court of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tahboub v. Thiagarajah, (Va. 2020).

Opinion

PRESENT: All the Justices

SHAREEF TAHBOUB, PERSONAL REPRESENTATIVE AND ADMINISTRATOR OF THE ESTATE OF JACLYN P. TAHBOUB OPINION BY v. Record No. 190019 JUSTICE WILLIAM C. MIMS February 13, 2020 SIVA THIAGARAJAH, ET AL.

FROM THE CIRCUIT COURT OF THE CITY OF CHARLOTTESVILLE Richard D. Taylor, Judge

In this medical malpractice appeal, we consider whether the plaintiff’s evidence was

sufficient to survive a motion to strike at the conclusion of his case-in-chief.

I. BACKGROUND AND MATERIAL PROCEEDINGS BELOW

Jaclyn Tahboub was diagnosed with an incompetent cervix during her first pregnancy in

2011. Siva Thiagarajah, M.D. surgically placed a cervical cerclage to prevent a premature birth. 1

Jaclyn later successfully delivered by Caesarean section and the cerclage was left in place.

In December 2013, Jaclyn was five months into her second pregnancy. Dr. Thiagarajah

could not locate the original cerclage during an ultrasound, so he surgically placed a new one on

December 12.

At a follow-up appointment on December 20, Jaclyn reported discomfort and pain

radiating to her abdomen, legs, and lower back, which she had not experienced after her 2011

cerclage procedure. Shareef Tahboub, Jaclyn’s husband, asked if she might have an infection,

which Dr. Thiagarajah denied without further investigation. On December 22, Jaclyn called Dr.

Thiagarajah and reported continuing pain in her abdomen, legs, and lower back, as well as a

1 A cervical cerclage is a suture placed around the cervix to prevent it from shortening and opening early. fever. Dr. Thiagarajah directed her to take Advil and prescribed nifedipine by telephone, without

conducting a physical examination.

Jaclyn continued to feel unwell. Early on the morning of December 26, she again called

for Dr. Thiagarajah but reached Mikhail Michael Levit, D.O., who was on call for him. She

again reported pain and fever. Dr. Levit told her to take Advil, Tylenol, and nifedipine, without

conducting a physical examination. Jaclyn called back not long after and Dr. Levit directed her

to go to Martha Jefferson Hospital (“MJH”).

Jaclyn arrived at the hospital by 3:08 a.m. and was assessed at 3:24. A nurse recorded

that Jaclyn was experiencing dizziness, light-headedness, tachycardia, hypotension, discomfort,

contractions, and had reported a fever and change in vaginal discharge. The nurse informed Dr.

Levit by telephone. He did not go to the hospital at that time and did not provide any

instructions beyond basic orders for admission.

Jaclyn’s membranes ruptured at 4:44 a.m., releasing a foul-smelling, yellow, pus-like

fluid, followed by a continuous discharge of green-brown fluid. Dr. Levit was informed by

telephone at 4:50. He did not go to the hospital at that time. By 5:27 a.m., Jaclyn had a

temperature of 100.8 °F. She was prepared for transfer to the University of Virginia Medical

Center (“UVAMC”) because delivery had become inevitable and it had superior neonatal

intensive care facilities. Dr. Levit arrived at MJH at 6:05 a.m.

When Jaclyn arrived at UVAMC, she presented with heavy bleeding, fever, ruptured

membranes, pus discharge, and multiple organ dysfunction. Doctors immediately suspected

chorioamnionitis and feared placental abruption and disseminated intravascular coagulopathy

2 (“DIC”). 2 Diane Rozycki, M.D. treated her for sepsis and chorioamnionitis by administering a

triple-antibiotic “cocktail” of ampicillin, gentamicin, and clindamycin, and a blood transfusion.

Blood cultures later confirmed bacterial infection with E. coli.

UVAMC staff performed an emergency delivery by Caesarean section, after which

Jaclyn suffered major hemorrhaging. She was admitted to the intensive care unit, where she

remained in critical condition until she died on December 31.

Shareef, as Jaclyn’s personal representative and the administrator of her estate, filed a

complaint alleging that Dr. Thiagarajah and Dr. Levit had been professionally negligent, which

had caused Jaclyn’s wrongful death. At trial, he adduced expert testimony from Frederick

Gonzalez, M.D., a specialist in fetal medicine, and Mohammad Sajadi, M.D., a specialist in

infectious disease, among other evidence. At the conclusion of his case-in-chief, the defendants

moved to strike the evidence, asserting that it was insufficient to prove causation. The court

granted the motion and entered a final order awarding judgment to the defendants.

We awarded Shareef this appeal.

II. ANALYSIS

As we recently observed, a motion to strike the plaintiff’s evidence replaces the abolished

demurrer to the evidence. See Sweely Holdings, LLC v. SunTrust Bank, 296 Va. 367, 382 n.12

(2018); see also Martin P. Burks, Pleading and Practice § 284, at 510 (4th ed. 1952) (citing

Green v. Smith, 153 Va. 675 (1930)). While the procedure and effect of these practices differed,

id. at 511-12, the function was the same. Thus, as a demurrer to a complaint tests whether the

plaintiff’s allegations are sufficient to state a cause of action, a motion to strike at the conclusion

2 Chorioamnionitis is an infection of the placenta and amniotic membranes and fluid. DIC is the loss of the blood’s ability to clot, which may be caused by infection or significant blood loss.

3 of the plaintiff’s case-in-chief, like a demurrer to the evidence, tests whether his evidence is

sufficient to prove it. See id. § 275, at 487.

Accordingly, just as “we accept as true all factual allegations expressly pleaded in the

complaint and interpret those allegations in the light most favorable to the plaintiff” when

reviewing a ruling on a demurrer to a complaint, Anderson v. Dillman, 297 Va. 191, 193-94

(2019), we review “the evidence and all reasonable inferences fairly deducible therefrom in the

light most favorable to the plaintiff” when reviewing a motion to strike at the conclusion of the

plaintiff’s case-in-chief. Artrip v. E.E. Berry Equip. Co., 240 Va. 354, 357 (1990). “Any

reasonable doubt as to the sufficiency of the evidence must be resolved in the plaintiff's favor.”

Id.

Consequently, even if the plaintiff’s evidence has been discredited or impeached by the

defendant during his cross-examination of the plaintiff’s witnesses, the court must accept it as

true at this phase of trial. The court must rule based on the presumption that the jury will believe

all the evidence that the plaintiff adduced. To do otherwise would invade the province of the

jury and assess the weight of the evidence. Compare Anderson v. Clinchfield R. Co., 171 Va. 87,

89 (1938) (rejecting the plaintiff’s argument that granting the motion in that case did so, ruling

that precedents limit the motion’s application) with Walton v. Walton, 168 Va. 419, 421-22

(1937) (cited in Clinchfield) (ruling that granting such a motion “and thereby taking the case

from the jury, is drastic and should not be done unless it is very plain that the court would be

compelled to set aside a verdict for plaintiff”) and CGI Fed. Inc. v. FCi Fed., Inc., 295 Va. 506,

509 (2018) (noting that when reviewing a ruling setting aside a verdict in his favor, we give the

plaintiff the benefit of “all substantial conflicts in the evidence”).

4 With these principles in mind, we turn to the evidence Shareef adduced with regard to

each of the defendants.

A. DR. THIAGARAJAH

Dr.

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Related

Bryan v. Burt
486 S.E.2d 536 (Supreme Court of Virginia, 1997)
Brown v. Koulizakis
331 S.E.2d 440 (Supreme Court of Virginia, 1985)
Artrip v. E.E. Berry Equipment Co.
397 S.E.2d 821 (Supreme Court of Virginia, 1990)
Hadeed v. Medic-24, Ltd.
377 S.E.2d 589 (Supreme Court of Virginia, 1989)
Dixon v. Sublett
809 S.E.2d 617 (Supreme Court of Virginia, 2018)
Sweely Holdings, LLC v. Suntrust Bank
820 S.E.2d 596 (Supreme Court of Virginia, 2018)
Green v. Smith
151 S.E. 282 (Supreme Court of Virginia, 1930)
Anderson v. Clinchfield Railroad
198 S.E. 478 (Supreme Court of Virginia, 1938)

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