Terry Cauffiel, as Administrator of the Estate of Carolyn Sue Cauffliel, and on Behalf of the Wrongful Death Beneficiaries of Carolyn Sue Cauffiel v. Progressive Eldercare Services-Saline, Inc.

2021 Ark. App. 314, 635 S.W.3d 1
CourtCourt of Appeals of Arkansas
DecidedSeptember 1, 2021
StatusPublished
Cited by3 cases

This text of 2021 Ark. App. 314 (Terry Cauffiel, as Administrator of the Estate of Carolyn Sue Cauffliel, and on Behalf of the Wrongful Death Beneficiaries of Carolyn Sue Cauffiel v. Progressive Eldercare Services-Saline, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Terry Cauffiel, as Administrator of the Estate of Carolyn Sue Cauffliel, and on Behalf of the Wrongful Death Beneficiaries of Carolyn Sue Cauffiel v. Progressive Eldercare Services-Saline, Inc., 2021 Ark. App. 314, 635 S.W.3d 1 (Ark. Ct. App. 2021).

Opinion

Cite as 2021 Ark. App. 314

Elizabeth Perry ARKANSAS COURT OF APPEALS I attest to the accuracy and DIVISION III integrity of this document No. CV-20-404 2023.07.06 12:31:40 -05'00' 2023.003.20215 Opinion Delivered September 1, 2021 TERRY CAUFFIEL, AS ADMINISTRATOR OF THE ESTATE APPEAL FROM THE SALINE OF CAROLYN SUE CAUFFIEL, AND COUNTY CIRCUIT COURT ON BEHALF OF THE WRONGFUL [NO. 63CV-13-355] DEATH BENEFICIARIES OF CAROLYN SUE CAUFFIEL HONORABLE GARY ARNOLD, JUDGE APPELLANT

V.

PROGRESSIVE ELDERCARE SERVICES- SALINE, INC., D/B/A HEARTLAND REHABILITATION AND CARE CENTER; SOUTHERN ADMINISTRATIVE SERVICES, LLC; REVERSED AND REMANDED AND CAREPLUS STAFFING SERVICES, LLC

APPELLEES

LARRY D. VAUGHT, Judge

Terry Cauffiel, acting as administrator of the estate of his mother, Carolyn Sue Cauffiel,

appeals the Saline County Circuit Court’s order granting Progressive Eldercare Services-Saline,

Inc., d/b/a Heartland Rehabilitation and Care Center (“Heartland”) a directed verdict on

Cauffiel’s resident’s-rights claim under the Arkansas Protection of Long-Term Care Facility

Residents Act (“Resident’s Rights Act”), 1999 Ark. Acts 1181, as amended (currently codified

at Ark. Code Ann. §§ 20-10-1201 to –1209 (Repl. 2018 & Supp. 2019). We reverse and remand. Carolyn Cauffiel was a resident of Heartland from February 29 to July 22, 2012. On

the morning of July 22, Ms. Cauffiel was rushed to the hospital in extreme respiratory distress

and passed away a few days later. Terry Cauffiel was named administrator of her estate and

filed suit against Heartland alleging negligence, medical malpractice, and violations of Ms.

Cauffiel’s statutory rights as a resident of a long-term-care facility. He also included several

other claims that were dismissed prior to trial and are not a part of this appeal.

Mr. Cauffiel tried these claims to a jury in May 2018. He presented expert testimony

from a nurse and a physician that breaches of the professional standard of care caused Ms.

Cauffiel to suffer medical injuries and death. Mr. Cauffiel also testified and presented the

testimony of other lay witnesses describing the terrible conditions in the nursing home and

illustrated how Ms. Cauffiel and other residents were routinely ignored, mocked, left to sit in

their own filth and waste, and suffered insults to their basic humanity and dignity.

At the close of the plaintiff’s case, Heartland requested a directed verdict on the

resident’s-rights claim, arguing that the legislature eliminated the independent cause of action

via a subsequent amendment to the Resident’s-Rights Act and that the claim was duplicative

of the negligence/medical-malpractice claim. The motion was denied but was renewed after

the close of Heartland’s case, and after several rounds of arguments on the motion, the circuit

court directed a verdict on the resident’s-rights claim because it said the jury would not be able

to distinguish between damages attributable to medical malpractice and damages attributable

to violations of the Resident’s Rights Act.

2 The remaining medical-malpractice claim was submitted to the jury, which found that

Heartland had breached the standard of care. The jury awarded $30,812.15 for Ms. Cauffiel’s

pain and suffering. Mr. Cauffiel now appeals the circuit court’s decision to direct a verdict in

favor of Heartland on the resident’s-rights claim.

A circuit court properly grants a directed verdict when the party bearing the burden of

proof fails to introduce sufficient evidence to put the cause of action to the jury. Farm Credit

Midsouth PCA v. Bollinger, 2018 Ark. App. 224, at 6, 548 S.W.3d 164, 170–71. “In determining

whether a directed verdict should have been granted, we review the evidence in the light most

favorable to the party against whom the verdict is sought and give it its highest probative value,

taking into account all reasonable inferences deducible from it.” Woodall v. Chuck Dory Auto

Sales, Inc., 347 Ark. 260, 264, 61 S.W.3d 835, 838 (2001). “A motion for directed verdict should

be granted only if there is no substantial evidence to support a jury verdict.” Id. “[I]f any

substantial evidence exists that tends to establish an issue in favor of [the opposing] party,

then a jury question is presented, and the directed verdict should be reversed.” Rose Care, Inc.

v. Ross, 91 Ark. App. 187, 210, 209 S.W.3d 393, 407 (2005) (emphasis in original). Likewise,

“[w]here the evidence is such that fair-minded persons might reach different conclusions, then

a jury question is presented.” Id. at 200, 209 S.W.3d at 400. A circuit court may also properly

grant a directed verdict when the court resolves a legal issue entitling the moving party to

judgment as a matter of law on a particular claim. D.B. Griffin Warehouse, Inc. v. Sanders, 336

Ark. 456, 464, 986 S.W.2d 836, 840 (1999).

3 The Resident’s Rights Act codified certain rights for Arkansans living in nursing

homes. Relevant to this appeal, the Resident’s Rights Act guarantees individuals living in

nursing homes (1) the right to be free from mental and physical abuse; and (2) the right to be

treated courteously, fairly, and with the fullest measure of dignity. Ark. Code Ann. § 20-10-

1204 (a)(14), (21) (Repl. 2018). At the time Cauffiel’s claims accrued in 2012 and when the

lawsuit was filed in 2013, the Resident’s Rights Act allowed for any resident injured by a

deprivation of the rights listed above to “bring a cause of action against any licensee

responsible for the deprivation or infringement.” Ark. Code Ann. § 20-10-1209(a) (Repl.

2005). In 2013, the Resident’s Rights Act was amended by Act 1196 to completely eliminate

this claim. In its current form, nursing-home residents may no longer recover for violations

of the Resident’s Rights Act. Instead, they have only one cause of action “under § 16-114-201

et seq.,” the Medical Malpractice Act. Ark. Code Ann. § 20-10-1209(a)(1) (Repl. 2018). The

current version makes it clear that a deprivation or infringement of a resident’s rights now

“does not itself create an additional cause of action.” Id. § 20-10-1209(d)(1). Rather than a

standalone claim with damages that do not depend on a showing of medical negligence,

violations of the Resident’s Rights Act are now only considered “evidence of negligence” as

part of a medical-malpractice claim. Id. § 20-10-1209(d)(2).

At trial, the circuit court granted a directed verdict on Cauffiel’s resident’s-rights claim

because it ruled that allowing the plaintiffs to proceed on both the negligence claim and the

resident’s-rights claim would likely confuse the jury and lead to an impermissible double

4 recovery. 1 On appeal, Cauffiel argues that the court erred in granting a directed verdict against

his resident’s-rights claim because the Arkansas Supreme Court has repeatedly recognized that

such a claim is separate and distinct from a negligence or medical-malpractice claim. Heartland

counters that (1) even if separate and distinct claims, it would be impermissible to allow for

double recovery for the same injury, and (2) the 2013 amendment to the Resident’s Rights Act

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