Justia Rhode Island Supreme Court Opinion Summaries

The plaintiffs, Jason Blouin and Heather Blouin, filed a medical malpractice lawsuit against several healthcare providers, alleging negligence in the births of their children, X.B. and D.B., who were born with cystic fibrosis. Heather Blouin received prenatal care from University OB-GYN, but was not offered genetic screening or counseling. X.B. was born in 2009 and later exhibited symptoms of cystic fibrosis, but was not diagnosed until 2013. D.B. was born in 2012 and was diagnosed with cystic fibrosis shortly after birth. The plaintiffs claimed that the healthcare providers' failure to diagnose and inform them of the genetic risks led to the births of X.B. and D.B. with cystic fibrosis.The Superior Court granted summary judgment in favor of the pediatric defendants, ruling that they did not owe a duty of care to the parents. The court also granted partial summary judgment in favor of the obstetric defendants, dismissing the wrongful-life claims based on the Rhode Island Supreme Court's decision in Ho-Rath v. Corning Incorporated, which held that no duty is owed to a child born with defects due to negligence in genetic counseling.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's decision. The Court held that the pediatric defendants did not owe a duty to the parents to diagnose X.B. with cystic fibrosis for the purpose of informing their reproductive decisions. The Court also upheld the dismissal of the wrongful-life claims, reiterating that life with impairments does not constitute a legally recognized injury under Ho-Rath III. The Court concluded that the trial justice correctly applied the law and that the plaintiffs' claims failed as a matter of law. View "Blouin v. Koster" on Justia Law

This case involves a medical negligence claim brought by John Armour, individually and as personal representative of the Estate of Judith Armour, against David Bader, M.D., Neil Brandon, M.D., and South County Hospital Healthcare System d.b.a. South County Cardiology. The plaintiff alleges that the defendants negligently failed to provide adequate follow-up and treatment to Judith Armour following a stress test, which ultimately led to her death from a heart attack the next day. The stress test results were "markedly abnormal" and indicated potential significant coronary artery disease, but Mrs. Armour was sent home after the staff determined she was medically stable.The case was tried in the Washington County Superior Court. The jury heard testimony from various witnesses, including the nurses, the defendant-doctors, Mrs. Armour’s family, and expert testimony from both sides regarding the applicable standard of care and causation. The jury returned a verdict in favor of the defendants on all counts. The plaintiff filed a motion for a new trial, arguing that the jury’s verdict was against the fair preponderance of the evidence and that the trial justice erred in several respects. The trial justice denied the motion, concluding that the overwhelming weight of the evidence supported the jury’s verdict.On appeal to the Supreme Court of Rhode Island, the plaintiff argued that the trial justice erred in refusing to issue a jury instruction based on a previous court decision, erred in permitting defendants’ standard-of-care expert to utilize the referring doctor’s records, and erred in limiting cross-examination of that expert regarding a particular study. The Supreme Court found that the trial justice's refusal to issue the requested jury instruction was prejudicial and constituted reversible error. The court also found that it was an error to allow the expert to use the referring physician’s records to support his opinions as defendants did not have access to this information when determining if Mrs. Armour was stable. Lastly, the court concluded it was an abuse of discretion to limit cross-examination on a point that went to the heart of the most important standard-of-care issue in the case. The judgment of the Superior Court was vacated and the case was remanded for a new trial. View "Armour v. Bader" on Justia Law

The Supreme Court quashed the decision of the superior court granting Defendant's motion to compel production of a complete, unreacted copy of a settlement agreement between Plaintiffs and the former codefendants who settled Plaintiffs' claims, holding that the trial justice abused her discretion in granting Defendant's motion.In granting Defendant's motion to compel production, the trial justice concluded that the amount paid in accordance with the settlement agreement was not discoverable "pursuant to Rhode Island and federal law." When Plaintiffs failed to comply with the order the superior court granted Defendant's motion to dismiss. The Supreme Court quashed the decision below and remanded the case, holding that the trial justice abused her discretion in granting Defendant's motion to compel production of a complete, unreacted copy of the settlement agreement. View "Noonan v. Sambandam" on Justia Law

The Supreme Court affirmed the judgment of the superior court in favor of Roger Williams Medical Center (RWMC) in this case alleging medical malpractice and negligent credentialing claims, holding that there was no error in the proceedings below.On appeal, Plaintiff argued that the motion justice erred in granting RWMC's motion for summary judgment on the ground that Plaintiff could not prove his negligent credentialing and medical malpractice claims without expert testimony. The Supreme Court affirmed, holding (1) expert testimony was required to prove Plaintiff's apparent agency claim against RWMC, and because Plaintiff failed to provide expert testimony, RWMC could not be held liable under an agency theory; and (2) Plaintiff's inability to present expert testimony establishing the standard of care applicable to RWMC in credentialing its doctors was fatal to Plaintiff's negligent credentialing claim. View "Dockray v. Roger Williams Medical Center" on Justia Law

The Supreme Court quashed the order of the superior court granting Defendant's motion for a protective order limiting the deposition testimony of Plaintiff's expert witness to causation opinions and prohibiting Plaintiff from further supplementing the expert witness's disclosure to include other opinions, holding that the trial justice erred.Plaintiff brought this medical malpractice action alleging negligence. The trial justice later granted Defendant's motion for a protective order seeking to preclude the expert witness from offering opinions regarding the standard of care and prohibited Plaintiff from supplementing the witness's disclosure to include opinions on topics outside of causation, including standard of care. The Supreme Court quashed the decision below, holding that the trial justice abused her discretion in granting Defendant's motion. View "Vecchio v. Women & Infants Hospital" on Justia Law

In the medical negligence action, the Supreme Court reversed the order of the superior court denying Plaintiffs' motion for a new trial following a jury verdict in favor of Defendant, holding that the trial justice was clearly wrong in denying Plaintiffs' motion for a new trial.Plaintiffs alleged that Defendant deviated from the appropriate standard of care by failing properly to perform and document assessments of a newborn's intravenous line site. The jury returned a verdict for Defendant. Plaintiffs subsequently filed a motion for a new trial on the grounds that Defendant repeatedly engaged in unfair and prejudicial action before the jury. The trial justice denied the motion. The Supreme Court reversed, holding that the trial justice erred in finding that Defendant's closing argument did not result in prejudice to Plaintiffs. View "Baker v. Women & Infants Hospital of R.I." on Justia Law

In this medical malpractice action, the Supreme Court vacated the order of the superior court granting Plaintiff's motion for a new trial after the jury found that Defendant breached the duty of care owed to the patient in this case, holding that the trial justice erred by replacing the jury's determination with her own.After Patricia Kinney died from complications related to her battle with ovarian cancer, Plaintiff brought this action, asserting that Defendant negligently performed a surgical procedure and post-surgical follow-up. The jury returned a verdict in favor of Plaintiff on the issue of negligence and for Defendant on the issue of proximate cause. The trial justice granted Plaintiff's motion for a new trial, finding that the verdict was against the fair preponderance of the evidence and failed to do substantial justice. The Supreme Court vacated the order, holding that reasonable minds could have come to different conclusions on the question of whether Plaintiff had met her burden of establishing that Defendant's breach was the cause of Kinney's death. View "Joplin v. Cassin" on Justia Law

The Supreme Court affirmed the judgment of the superior court denying Plaintiff’s motion for a new trial after the jury returned a verdict in favor of Defendants in this medical malpractice action.Plaintiff’s claim against Defendants arose from an injury she alleged she suffered when she underwent an emergency cesarean section. The jury returned a verdict for Defendants. Plaintiff moved for a new trial. The trial justice denied the motion, concluding that reasonable minds could differ as to whether Plaintiff’s doctor’s conduct fell below the appropriate standard of care. The Supreme Court affirmed, holding (1) the trial justice did not err in determining that reasonable minds could differ as to whether the doctor complied with the standard of care; and (2) the trial justice did not abuse his discretion in his evidentiary rulings. View "Cappuccilli v. Carcieri" on Justia Law

The Supreme Court affirmed the superior court’s grant of summary judgment in favor of Dr. David Coppe (Defendant) in this medical malpractice action. Plaintiffs alleged that Defendant breached the standard of care for treatment of a cellulitis ulcer, which required right foot bone amputation. The hearing justice granted summary judgment for Defendant after precluding Plaintiffs from relying on expert witness testimony in the case. The Supreme Court held (1) any challenge to the ruling precluding Plaintiffs’ proposed expert witness was waived; (2) Plaintiffs were permitted to argue the facts of their case, and the grant of summary judgment was not in error; and (3) there was no evidence that the hearing justice was biased against Plaintiffs. View "Bartlett v. Coppe" on Justia Law

Plaintiff brought this medical malpractice lawsuit against Defendants, his optometrist and his optometrist’s employer, arguing that his optometrist breach the duty of care to him because he failed to diagnose a detached retina, which resulted in permanent vision loss. The jury returned a verdict in favor of Defendants, concluding that although the optometrist violated the standard of care in treating Defendant, that violation was not the cause of Plaintiff’s vision loss. The Supreme Court vacated the judgment and remanded for a new trial, holding that the trial justice erred by restricting the testimony of Plaintiff’s causation expert, and Plaintiff was entitled to a new trial on all issues. View "Ribeiro v. Rhode Island Eye Inst." on Justia Law