Justia Rhode Island Supreme Court Opinion Summaries

Articles Posted in Medical Malpractice
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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

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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

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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

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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

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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

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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

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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

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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

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Plaintiffs initiated a medical malpractice suit against numerous medical organizations and professionals twelve years after their daughter, Yendee, was born with a genetic disorder. Plaintiffs alleged negligence in the diagnosis and treatment relating to Yendee’s genetic disorder and also asserted their own claims for loss of consortium. The superior court granted Defendants’ motion to dismiss, concluding (1) Plaintiffs’ claims were barred by the statute of limitations set forth in R.I. Gen. Laws 9-1-14.1; and (2) in light of Yendee’s status as a minor, the tolling provision in section 9-1-14.1(1) would allow Yendee to file suit in the future on her own behalf upon reaching the age of majority, but Yendee’s parents would not be permitted to attach their loss-of-consortium claims to Yendee’s future suit. The Supreme Court affirmed, holding (1) under section 9-1-14.1(1), a minor’s parent or guardian may file suit on the minor’s behalf within three years of the occurrence or reasonable discovery of alleged malpractice, or the minor may file suit on her own behalf, but not until she reaches the age of majority; but (2) Plaintiffs’ claims may be asserted alongside Yendee’s claims if she elects to file suit upon reaching the age of majority. View "Ho-Rath v. Rhode Island Hospital" on Justia Law

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Plaintiff filed a civil action against a physician and his employer alleging that Defendants negligently failed to protect the confidentiality of his HIV test results and seeking to recover both compensatory and exemplary damages. The superior court granted Defendant's motion to strike Plaintiff’s claims for exemplary damages and severed Plaintiff’s claim for exemplary damages without holding an evidentiary hearing pursuant to Palmisano v. Toth. The Supreme Court quashed the order of the superior court, holding that the hearing justice erred failing to conduct an evidentiary hearing in accordance with the Court’s holding in Palmisano on Plaintiff’s claim for exemplary damages. Remanded. View "Sherman v. Ejnes" on Justia Law