The Estate of Willie Walters v. West Louisiana Health Services, Inc., Etc.

CourtLouisiana Court of Appeal
DecidedMay 1, 2013
DocketCA-0012-1457
StatusUnknown

This text of The Estate of Willie Walters v. West Louisiana Health Services, Inc., Etc. (The Estate of Willie Walters v. West Louisiana Health Services, Inc., Etc.) 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
The Estate of Willie Walters v. West Louisiana Health Services, Inc., Etc., (La. Ct. App. 2013).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

12-1457

THE ESTATE OF WILLIE WALTERS

VERSUS

WEST LOUISIANA HEALTH SERVICES, INC., d/b/a BEAUREGARD MEMORIAL HOSPITAL

**********

APPEAL FROM THE THIRTY-SIXTH JUDICIAL DISTRICT COURT PARISH OF BEAUREGARD, NO. 2012-0078 HONORABLE C. KERRY ANDERSON, DISTRICT JUDGE

JOHN E. CONERY JUDGE

Court composed of Sylvia R. Cooks, James T. Genovese, and John E. Conery, Judges.

REVERSED AND REMANDED.

Darrell Keith Hickman Hickman Law Office 620 Murphy Street Post Office Box 48 Alexandria, Louisiana 71309-0048 (318) 448-6353 COUNSEL FOR PLAINTIFF/APPELLANT: The Estate of Willie Walters René Joseph Pfefferle Jennifer M. Durham Watson, Blanche, Wilson & Posner 505 North Boulevard Post Office Box 2995 Baton Rouge, Louisiana 70821-2995 (225) 387-5511 COUNSEL FOR DEFENDANT/APPELLEE: West Louisiana Health Services, Inc., d/b/a Beauregard Memorial Hospital CONERY, Judge.

This medical malpractice action was filed on behalf of The Estate of Willie

Walters (Estate), by his wife Opal Walters, who was designated as succession

administrator only for the purpose of pursuing this action against West Louisiana

Health Services, Inc., d/b/a Beauregard Memorial Hospital (Beauregard). The trial

court granted Beauregard’s motion for summary judgment dismissing Mr. Walters’

claim on the basis that the Estate failed to submit an expert medical opinion to

support the claim that a breach of the standard of care caused injury to Mr.

Walters. For the following reasons, we reverse and remand.

FACTS AND PROCEDURAL HISTORY

On June 15, 2009, Mr. Walters was admitted by Dr. Flynn Taylor, a family

practitioner, to Beauregard with complaints of cough, congestion, fever, and

breathing difficulties. Dr. Taylor diagnosed Mr. Walters with pneumonia and

chronic obstructive pulmonary disease (COPD). The family reported that Mr.

Walters had previously fallen at home. Mr. Walters was determined to be

ambulatory, but he required some assistance with ambulation and was assessed to

be at high risk for falls. Having determined that Mr. Walters was at high risk for

falls, the hospital was required to implement a fall prevention procedure, including

several fall prevention steps. Beauregard contends that these steps included

placing the bedside rails up times three, placing the bed in the low position, placing

a commode near the bedside, and putting the nurse call light within Mr. Walters’

reach, so that Mr. Walters could call the nurses for assistance. He was allegedly

instructed to call the nurses whenever he needed assistance.

On June 20, 2009, a nurse found Mr. Walters on the floor next to his bedside

commode. He had suffered a non-displaced fracture of his left hip and was subsequently transferred to Lake Charles Memorial Hospital by his treating

physician, Dr. Taylor, for surgery on his fractured hip.

On or about June 11, 2010, in accordance with La.R.S. 40:1299.47, the

Estate filed a complaint of medical malpractice against Beauregard with the

Division of Administration. The Estate requested a medical review panel (MRP)

and alleged that Beauregard breached the standard of care owed to Mr. Walters by

allowing him to fall and fracture his hip. Evidently, Mr. Walters died of unrelated

causes prior to the filing of the Estate’s complaint with the Division of

Administration.1

The medical review panel, consisting of three physicians, Drs. Kelvin

Spears, Gerald Mouton, and Vincent Lococo, reviewed Mr. Walters’ complaint,

and on October 12, 2011, the panel issued an opinion, unanimously finding that,

based on the evidence presented, Beauregard did not breach the applicable

standard of care in its treatment of Mr. Walters.

On January 26, 2012, the Estate timely filed suit, claiming medical

malpractice against Beauregard. Beauregard answered the Estate’s suit on

February 28, 2012, and propounded interrogatories seeking the name of all experts

the Estate intended to use at the time of trial.

On June 28, 2012, Beauregard filed a motion for summary judgment on the

grounds that the Estate had no expert testimony to support its claim as required by

La.R.S. 9:2794(A). In support of its motion for summary judgment, Beauregard

relied on the opinion of the medical review panel that the hospital had not breached

the standard of care in its treatment of Mr. Walters.

1 The Estate’s Petition for Damages indicates Mr. Walters’ death and designates his certificate of death as Exhibit “A.” However, the record before us does not contain the referenced death certificate.

2 Beauregard’s motion for summary judgment was set for hearing on

September 13, 2012. On September 11, 2012, the Estate filed a motion and order

for continuance on the grounds that its expert, Mae A. Williams, Associate Chief,

Nursing Services for Education, and Acting Chief of Education Service for the

Alexandria Veterans Administration Health Care System in Pineville, Louisiana

(Nurse Williams), did not have adequate time to review the records from

Beauregard in time for the hearing. Beauregard opposed the motion for

continuance as untimely, citing the failure of the Estate to have an expert review

the case despite three years having passed since the alleged malpractice and eleven

months since the medical review panel issued its opinion in favor of Beauregard.

The hearing on Beauregard’s motion for summary judgment was held, as

scheduled, on September 13, 2012. The trial court denied the Estate’s motion for a

continuance, but left the record open for seven days to allow Nurse Williams the

opportunity to review the records and to allow the Estate to file into the record an

affidavit of Nurse Williams in opposition to Beauregard’s motion for summary

judgment.

On September 20, 2012, the Estate filed its opposition to Beauregard’s

motion, asserting expert testimony was not required in this case, and, in the

alternative, the affidavit of Nurse Williams established that Beauregard breached

the applicable standard of care. Beauregard filed a reply brief on September 21,

2012, urging that the affidavit of Nurse Williams did not create a genuine issue of

material fact for trial.

On September 26, 2012, in its written Reasons For Judgment and Judgment,

the trial court granted Beauregard’s motion for summary judgment on the basis

3 that the Estate failed to produce expert medical testimony refuting the opinion of

the medical review panel.

ASSIGNMENTS OF ERROR

1. The district court erred when it relied upon the defendant’[s] inadequate medical record keeping [and] dismissed the plaintiff’s claim on defendant’s motion for summary judgment.

2. The district court erred when it failed to recognize that a medical facility that fails to maintain adequate medical records breaches the standard of care for medical professionals.

In other words, the Estate urges that the trial court erred in relying on

inadequate medical records in reaching its ruling and in not recognizing that

Beauregard’s failure to maintain adequate medical records is a breach of the

standard of care. Thus, a genuine issue of material fact was created by Nurse

Williams’ affidavit which questioned the quality and completeness of the nurses’

notes pertaining to the care of Mr. Walters while he was a patient at Beauregard.

By inference, there is a factual dispute as to whether an appropriate high-fall risk

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

Related

Perritt v. Dona
849 So. 2d 56 (Supreme Court of Louisiana, 2003)
Smith v. State Through Dept. HHR
523 So. 2d 815 (Supreme Court of Louisiana, 1988)
SJ v. Lafayette Parish School Bd.
959 So. 2d 884 (Supreme Court of Louisiana, 2007)
South Louisiana Bank v. Williams
591 So. 2d 375 (Louisiana Court of Appeal, 1991)
Cook v. JEFFERSON PARISH HOS. SERVICE DIST.
876 So. 2d 173 (Louisiana Court of Appeal, 2004)
Hutchinson v. KNIGHTS OF COLUMBUS, NO. 5747
866 So. 2d 228 (Supreme Court of Louisiana, 2004)
Hunt v. Bogalusa Community Medical Center
303 So. 2d 745 (Supreme Court of Louisiana, 1974)
Borne v. St. Francis Medical Center
655 So. 2d 597 (Louisiana Court of Appeal, 1995)
Davenport v. Albertson's, Inc.
774 So. 2d 340 (Louisiana Court of Appeal, 2000)
Martin v. East Jefferson General Hosp.
582 So. 2d 1272 (Supreme Court of Louisiana, 1991)
Hardy v. Bowie
744 So. 2d 606 (Supreme Court of Louisiana, 1999)
McGlothlin v. Christus St. Patrick Hospital
65 So. 3d 1218 (Supreme Court of Louisiana, 2011)
Holmes v. State
988 So. 2d 1252 (District Court of Appeal of Florida, 2008)

Cite This Page — Counsel Stack

Bluebook (online)
The Estate of Willie Walters v. West Louisiana Health Services, Inc., Etc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-estate-of-willie-walters-v-west-louisiana-health-services-inc-etc-lactapp-2013.