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Keywords

plaintiffdefendantnegligencetrialsummary judgmentrehabilitation
plaintiffdefendantdamagesnegligencetrialmotionsummary judgmentmotion for summary judgmentrehabilitation

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Glenn v. Peoples, 185 So.3d 981

Facts

Mattie Hazel Aldridge was treated by Dr. James T. Peoples for a recurrent deep-vein thrombosis at St. Dominic Hospital, where he prescribed anticoagulation therapy. After being discharged and transferred to Trinity Mission Health & Rehabilitation, Aldridge later presented with a brain bleed and subsequently died. Tamara Glenn, Aldridge's daughter, filed a wrongful death suit against Dr. Peoples, alleging negligence in his prescription of Coumadin, which she claimed caused her mother's death.

On April 24, 2010, Dr. James T. Peoples treated Mattie Hazel Aldridge (“Aldridge”) when she presented to St. Dominic Hospital with a recurrent deep-vein thrombosis. During her stay at the hospital, Dr. Peoples placed Aldridge on anticoagulation therapy. Almost two months later, on June 25, 2010, after she had been transferred into the care of Trinity Mission Health & Rehabilitation of Clinton (“Trinity”), Aldridge presented to St. Dominic with a brain bleed.

Issue

Did the trial court err in granting summary judgment to Dr. Peoples on the claims of negligent prescription and negligent monitoring?

whether the trial court erred in granting summary judgment to Dr. Peoples on the negligent-prescription and negligent-monitoring claims.

Rule

To establish a prima facie case of medical negligence, the plaintiff must show that the defendant had a duty to conform to a specific standard of conduct, failed to conform to that standard, that the breach was a proximate cause of the plaintiff's injury, and that the plaintiff was injured as a result.

To establish a prima facie case of medical negligence, the plaintiff must show that: (1) the defendant had a duty to conform to a specific standard of conduct for the protection of others against an unreasonable risk of injury; (2) the defendant failed to conform to that required standard; (3) the defendant's breach of duty was a proximate cause of the plaintiff's injury, and; (4) the plaintiff was injured as a result.

Analysis

The court analyzed whether Dr. Peoples's prescription of Coumadin was negligent and if it proximately caused Aldridge's injuries. It found that while there was a genuine issue of fact regarding the standard of care, there was insufficient evidence to establish that Dr. Peoples's actions were the proximate cause of Aldridge's stroke. The court noted that Dr. Jones, who took over Aldridge's care, was responsible for her medication and monitoring after her transfer.

But the inquiry does not end here. No citation of authority is necessary for the well-understood principle of negligence law that a plaintiff may not recover without demonstrating that the defendant's negligence was a proximate cause of the plaintiff's damages.

Conclusion

The Supreme Court affirmed the trial court's decision, concluding that Dr. Peoples's prescription of Coumadin did not proximately cause Aldridge's stroke and subsequent death.

In sum, Glenn failed to present sufficient evidence to create a genuine issue of material fact regarding causation, and the trial court, therefore, properly granted Dr. Peoples's motion for summary judgment.

Who won?

Dr. James T. Peoples prevailed in the case because the court found that there was no evidence linking his prescription of Coumadin to Aldridge's brain bleed, as the medication would have cleared from her system before the incident occurred.

Dr. Peoples correctly argues that Glenn failed to put forth sufficient evidence to create a genuine issue of material fact as to whether Dr. Peoples's act of prescribing Coumadin—even assuming for the sake of this argument that it was a negligent act—proximately caused Aldridge's injuries.

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