Vivian Meyers v. Golden Palms Retirement & Health Center, Inc.

CourtCourt of Appeals of Texas
DecidedMay 24, 2007
Docket13-06-00289-CV
StatusPublished

This text of Vivian Meyers v. Golden Palms Retirement & Health Center, Inc. (Vivian Meyers v. Golden Palms Retirement & Health Center, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Vivian Meyers v. Golden Palms Retirement & Health Center, Inc., (Tex. Ct. App. 2007).

Opinion



NUMBER 13-06-289-CV



COURT OF APPEALS



THIRTEENTH DISTRICT OF TEXAS



CORPUS CHRISTI
- EDINBURG



VIVIAN MEYERS, Appellant,



v.



GOLDEN PALMS RETIREMENT

& HEALTH CENTER, INC., Appellee.

On appeal from the 197th District Court

of Cameron County, Texas.



MEMORANDUM OPINION



Before Chief Justice Valdez and Justices Yañez and Vela

Memorandum Opinion by Justice Vela



This is an appeal from the dismissal of a medical malpractice case. Tex. Civ. Prac. & Rem. Code Ann. § 74.351 (Vernon Supp. 2006). The trial court dismissed appellant's case after it determined that the expert reports did not satisfy the statutory requirements. In three issues, appellant argues that the court improperly dismissed the case based on unspecified deficiencies in the reports, failed to grant her an extension of time to cure the deficiencies in the reports, and failed to make findings of fact and conclusions of law. We affirm.

I.

BACKGROUND



Appellant, Vivian Meyers, was transferred to Golden Palms Retirement and Health Center in Harlingen ("Golden Palms"), appellee, to convalesce after undergoing surgery to revise the prosthesis in her left hip. Meyers alleged that on February 14, 2004, a nurse assistant moved her from a wheel chair to her bed in contravention of a directive in her Minimum Data Set ("MDS"), which required that two persons assist in her transfer. (1) Meyers asserted that, during the lift, she heard and felt a crack in her leg. Two days later, she was diagnosed with a fracture to her left femur that required surgical repair. At the time of this incident Meyers was 73 years old. The MDS identified Meyers as totally dependent on the staff for assistance and directed that at least two persons assist in transferring her to and from her bed, chair and wheelchair. Meyers' initial plan of care listed her femur as very fragile.

Meyers sued Golden Palms on November 22, 2005. She alleged that as a result of Golden Palms' negligence she suffered a fractured femur, was forced to undergo surgery, and continues to suffer the residual effects of her injury. Meyers filed four expert reports in an attempt to comply with Texas Civil Practice and Remedies Code section 74.351. Golden Palms challenged the reports and moved to dismiss. After a hearing, the trial court granted Golden Palms' motions. Before the trial court signed its order, Meyers moved for a rehearing which included a request for an extension pursuant to section 74.351 of the Texas Civil Practice and Remedies Code. The trial court dismissed Meyers' claim with prejudice.

II.



THE LAW



The expert report requirements in medical malpractice cases are well settled. The issue for the trial court is whether the report represents a good faith effort to comply with the statutory definition. Bowie Mem'l Hosp. v. Wright, 79 S.W.3d 48, 52 (Tex. 2002). To constitute a good faith effort, the report must provide enough information to fulfill two purposes: (1) it must inform the defendant of the specific conduct called into question, and (2) it must provide a basis for the trial court to conclude that the claims have merit. American Transitional Care Ctrs. of Tex., Inc. v. Palacios, 46 S.W.3d 873, 879 (Tex. 2001). All information relevant to the inquiry is contained within the document's four corners. Id. at 878. The report must include an expert opinion on the standard of care, breach and causal relationship. Id. A report cannot merely state the expert's conclusions about these elements. Id. Rather, the expert must explain the basis of his or her statement to link those conclusions to the facts. Bowie Mem'l Hosp. v. Wright, 79 S.W.3d at 52.

It is necessary to have expert testimony regarding causation in a medical malpractice case. Hart v. Van Zandt, 399 S.W.2d 791, 792 (Tex. 1965). Causation is established by proof that the negligent act or omission was a substantial factor in bringing about the harm and without which the harm would not have occurred. Kramer v. Lewisville Mem'l Hosp., 858 S.W.2d 397, 400 (Tex. 1993). Only a physician qualified to render opinions on such causal relationship may testify as to causation. Tex. Civ. Prac. & Rem. Code Ann. § 74.351(r)(5)(C) (Vernon Supp. 2006). Liability in a malpractice case may not turn upon speculation or conjecture. Hutchinson v. Montemayor, 144 S.W.3d 614, 618 (Tex.App.-San Antonio 2004, no pet.).

III.



CAUSATION ANALYSIS



1. Standard of Review

In resolving the issue of whether the trial court's decision that the report did not meet the test set forth for initial expert reports, we follow an abuse of discretion standard of review. Palacios, 46 S.W.3d at 878. Under this standard, we determine whether the trial court acted arbitrarily or without reference to any guiding rules or principles. Walker v. Gutierrez, 111 S.W.3d 56, 62 (Tex. 2003). We may not reverse a trial court's discretionary ruling simply because we might have decided it differently. Id. In other words, we review whether the trial court could have reasonably determined that the report did not represent a good faith effort to summarize the causal relationship between Golden Palms' alleged failure to meet the applicable standard of care and the injury to Mrs. Meyers.

Discretion, at its most basic level, means choice. Trial court discretion is important because it is impossible for appellate courts to monitor all trial court rulings in a precise manner because the facts and circumstances are so varied. While there has been some discussion about whether a more rigorous standard should be applied to the trial court's determination in order to preserve the balance between the elimination of frivolous lawsuits and a litigant's right to trial on the merits, to date, the abuse of discretion standard remains in place. See George C. Hanks, Jr. & Rachel Polinger-Hyman,

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