Williamson v. Amrani

152 P.3d 60, 283 Kan. 227, 2007 Kan. LEXIS 26
CourtSupreme Court of Kansas
DecidedFebruary 9, 2007
Docket95,154
StatusPublished
Cited by37 cases

This text of 152 P.3d 60 (Williamson v. Amrani) is published on Counsel Stack Legal Research, covering Supreme Court of Kansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Williamson v. Amrani, 152 P.3d 60, 283 Kan. 227, 2007 Kan. LEXIS 26 (kan 2007).

Opinions

Per Curiam:

This case raises the question of whether the Kansas Consumer Protection Act (KCPA), K.S.A. 50-623 et seq., applies to a physician s professional conduct in providing treatment to a patient, specifically whether a physician can be found to have engaged in deceptive acts and practices in violation of K.S.A. 50-626 and unconscionable acts and practices in violation of K.S.A. 50-627 by knowingly making misrepresentations regarding the proposed medical treatment or willfully concealing or failing to make disclosures of material facts. We conclude die KCPA can apply to a physician’s conduct in providing treatment. We further conclude that expert testimony may be necessary to prove the claim.

This case arose after Tracy Williamson sought treatment from Jacob Amrani, M.D., for a disabling back injury Williamson had [228]*228sustained 14 years earlier. Dr. Amrani recommended that Williamson undergo lower back surgery for an L4-5 and L5-S1 fusion involving BAK cages (a surgical device) and an iliac crest bone graft. Dr. Amrani performed this surgery on Williamson in May 1999. When Dr. Amrani saw Williamson again in August 1999, she was still experiencing pain in her lower back and left leg. Dr. Amrani recommended a second surgery involving removal of the BAK cage at L4-5. Dr. Amrani performed the second surgery in October 1999.

Williamson filed suit against Dr. Amrani. In an amended petition, Williamson alleged that Dr. Amrani engaged in deceptive acts and practices in violation of K.S.A. 50-626 and unconscionable acts and practices in violation of K.S.A. 50-627 by making representations to Williamson that the surgery he would perform would have benefits that, in fact, it did not have. Specifically, Williamson alleged that Dr. Amrani represented that the surgery he was recommending had a high likelihood of successfully relieving her pain when, in fact, that surgery had been unsuccessful in the majority of cases where Dr. Amrani had utilized the same procedure. Williamson alleged that Dr. Amrani had willfully misrepresented or concealed material facts in that he knew or should have known that the surgery he was recommending had produced “bad results” for a majority of his patients.

At the time of her deposition Williamson testified that, prior to the first surgery, Dr. Amrani told her the surgery would reheve her pain to the point where she would no longer need pain medication and would be able to return to work.

Dr. Amrani filed a motion for summary judgment arguing that the KCPA does not apply to a physician’s professional conduct in providing care and treatment to patients and that Williamson’s KCPA claims were an impermissible attempt to creatively plead medical negligence (malpractice).

District Judge Timothy G. Lahey overruled Dr. Amrani’s motion, finding that the KCPA applied. Noting that the KCPA must be liberally construed to bring consumer transactions within its scope, Judge Lahey found that, under the KCPA, the physician is a supplier and the patient is a consumer. Further, he found that [229]*229while the KCPA has some explicit exclusions, nothing in the KCPA excludes the physician-patient relationship from its scope. Judge Lahey found there was a genuine issue of material fact as to what Dr. Amrani told Williamson about the surgeiy; therefore, whether there was a violation of the KCPA was a question for the jury.

Dr. Amrani subsequently filed a second motion for partial summary judgment arguing that, even if the KCPA applied, Williamson would be required to produce expert testimony to establish her claim that Dr. Amrani should have informed her of his personal experience and success rate in performing the medical procedure at issue. Williamson had not identified any such expert witness.

Judge Lahey granted Dr. Amrani’s motion, ruling that, while expert testimony would not be required to establish whether Dr. Amrani affirmatively misrepresented his level of experience or success rate in recommending the surgery to Williamson, expert testimony would be required to establish whether his failure to make an affirmative disclosure of his level of experience or success rate constituted a deceptive or unconscionable act or practice. Judge Lahey stated: “In the absence of expert testimony establishing a duty on the part of the doctor to disclose his experience to a patient, plaintiff does not establish a deceptive act.”

Prior to the scheduled trial, Dr. Amrani filed several motions in limine to exclude certain evidence. At a hearing on those motions, a different judge, District Judge Warren M. Wilbert, informed the parties that he had recently ruled in another case that the KCPA does not apply to a physician’s professional treatment of a patient, that he remained strongly of that view, and that he would likely rule that way at the time of a motion for directed verdict. In order to avoid the cost of trial and to conserve judicial resources, the parties agreed it would be more appropriate for the court to take up the matter on Dr. Amrani’s request to reconsider his motion for summary judgment. Judge Wilbert then ruled that Dr. Amrani was entitled to judgment as a matter of law, making the following conclusions of law:

“1. The issues of what disclosures a surgeon should malee to a patient regarding risks, benefits and the likelihood of success of tire proposed surgery falls under an area of the law of medical malpractice known as informed consent. A claim [230]*230that a physician provided inadequate or inappropriate informed consent involves the professional aspect of a physician’s practice as opposed to the proprietary, business aspects of the physician’s practice;
“2. The Kansas Consumer Protection Act may under certain circumstances apply to the conduct of a physician in dealing with a patient. Application of the act, however, is limited to tire proprietary and business aspects of a physician’s practice and does not apply to the physician’s professional conduct in providing treatment to a patient;
“3. The issue of whether, under the particular circumstances of this case, Dr. Jacob Amrani, as an orthopedic surgeon, should have provided a less optimistic appraisal of tire likelihood of the surgery providing pain relief and other benefits is a subject intrinsically associated with professional judgment and tire standard of care of such nature as to, first, necessitate expert testimony and, second, be of a type the Kansas Legislature did not intend to have adjudicated under the terms of the Kansas Consumer Protection Act.”

Williamson timely appealed the district court’s ruling granting summary judgment in favor of Dr. Amrani.

Application of the KCPA

First, Williamson essentially contends the district court’s summary judgment ruling in favor of Dr. Amrani was inappropriate in light of the KCPA’s application to a physician’s professional conduct in providing treatment to a patient.

Standard of Review

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

Related

S.B. v. Sedgwick Co. Area Educ. Svcs.
Court of Appeals of Kansas, 2024
DANTE v. SCHWARTZ
D. New Jersey, 2022
Astorga v. Leavenworth County Sheriff
Court of Appeals of Kansas, 2020
Smart v. BNSF Railway Co.
369 P.3d 966 (Court of Appeals of Kansas, 2016)
Nieberding v. Barrette Outdoor Living, Inc.
302 F.R.D. 600 (D. Kansas, 2014)
Ho v. Michelin North America, Inc.
520 F. App'x 658 (Tenth Circuit, 2013)
Wilson v. Ampride, Inc.
867 F. Supp. 2d 1124 (D. Kansas, 2012)
LOUISBURG BLDG. & DEV'T CO. v. Albright
252 P.3d 597 (Court of Appeals of Kansas, 2011)
Via Christi Regional Medical Center, Inc. v. Reed
247 P.3d 1064 (Court of Appeals of Kansas, 2011)
Tudor v. Wheatland Nursing L.L.C.
214 P.3d 1217 (Court of Appeals of Kansas, 2009)
Gaumer v. ROSSVILLE TRUCK AND TRACTOR CO.
202 P.3d 81 (Court of Appeals of Kansas, 2009)
Double M Construction, Inc. v. State Corp. Commission
202 P.3d 7 (Supreme Court of Kansas, 2009)
Kelly v. Vinzant
197 P.3d 803 (Supreme Court of Kansas, 2008)
Spires v. Hospital Corp. of America
289 F. App'x 269 (Tenth Circuit, 2008)

Cite This Page — Counsel Stack

Bluebook (online)
152 P.3d 60, 283 Kan. 227, 2007 Kan. LEXIS 26, Counsel Stack Legal Research, https://law.counselstack.com/opinion/williamson-v-amrani-kan-2007.