Justia District of Columbia Court of Appeals Opinion Summaries

A patient was admitted to a hospital after suffering chest pains and remained hospitalized for three months until his death. During his stay, he developed a severe Stage 4 sacral ulcer. The patient’s widow, acting individually and as personal representative of his estate, filed suit against the hospital and associated medical providers for negligence and medical malpractice, alleging that failures in wound care, skin monitoring, and repositioning caused the ulcer and contributed to his suffering and death. She also asserted a claim for lack of informed consent regarding risks of long-term hospitalization.The case was first reviewed by the Superior Court of the District of Columbia. During proceedings, the plaintiff shifted her theory to res ipsa loquitur, arguing that negligence could be inferred solely from the development of a Stage 4 ulcer during hospitalization. The Superior Court rejected application of res ipsa loquitur, expressing skepticism about the informed consent claim, and granted summary judgment for the defendants. The court also excluded the plaintiff’s expert testimony but gave little explanation for its reasoning.On appeal, the District of Columbia Court of Appeals conducted de novo review and affirmed the Superior Court’s judgment. The appellate court held that the plaintiff failed to establish a triable res ipsa loquitur case because her experts did not sufficiently address the patient’s multiple comorbidities, which were shown by defense evidence to have contributed to the unavoidable development and worsening of the ulcer. The court also held that the lack of informed consent claim failed due to the absence of expert testimony establishing that long-term hospitalization posed distinct risks compared to alternative care, or that the patient had a meaningful choice. Thus, summary judgment for the defendants was affirmed. View "Pearson v. Medstar Washington Hospital Center" on Justia Law

David Kaplan brought a lawsuit against MedStar Georgetown Medical Center, Inc. and an affiliated medical group, alleging that they failed to meet the national standard of care in treating his Crohn’s disease and did not obtain his informed consent for treatment. As a result of the alleged medical negligence, Kaplan endured prolonged use of steroids, which did not alleviate his condition and ultimately led to the complete deterioration of his hip bones. He subsequently required three hip replacement surgeries, experiencing significant physical pain, emotional distress, and limitations on his lifestyle and activities.The Superior Court of the District of Columbia presided over a jury trial, where the jury found MedStar liable for both breaching the standard of care and failing to obtain informed consent. The jury awarded Kaplan $4 million in damages, allocating separate amounts for past and future physical injury and for past and future emotional distress. MedStar timely objected to the verdict form, aspects of Kaplan’s closing argument, and the amount of damages, and subsequently filed a post-trial motion seeking judgment as a matter of law or, alternatively, a reduction in damages. The trial court denied these motions.The District of Columbia Court of Appeals reviewed the case and affirmed the Superior Court’s judgment. The appellate court held that the trial court did not abuse its discretion by allowing the verdict form to separately list damages for physical injury and emotional distress, as these are conceptually distinct forms of harm. The court further found that any improper argument in Kaplan’s closing was adequately addressed by curative instructions, and that the damages award was not so excessive as to shock the conscience or require remittitur. The judgment in favor of Kaplan was affirmed in its entirety. View "Medstar Georgetown Medical Center, Inc. v. Kaplan" on Justia Law

In 2003, Sarah Ramey underwent a urethral dilation performed by Dr. Edward Dunne, which resulted in severe pain and subsequent debilitating medical conditions. Over the next fourteen years, Ramey sought medical advice from numerous doctors to determine the cause of her ailments. In 2017, Drs. Mario Castellanos and Lee Arnold Dellon linked her symptoms to the 2003 procedure. Ramey filed a lawsuit against Dr. Dunne and Foxhall Urology in 2019.The Superior Court of the District of Columbia held a bifurcated trial to determine if Ramey’s claim was barred by the statute of limitations. The jury found that Ramey failed to file her suit within the three-year statute of limitations. Ramey then filed a motion for judgment as a matter of law or, alternatively, for a new trial, arguing that the trial court erred in its rulings and jury instructions. The trial court denied her motion.The District of Columbia Court of Appeals reviewed the case. The court held that the trial court did not err in denying Ramey’s motion for judgment as a matter of law, as there was sufficient evidence for a reasonable jury to find that Ramey had received medical opinions linking her symptoms to the urethral dilation before 2017. The court also found that Ramey waived her claim regarding the jury instructions by affirmatively agreeing to them during the trial.However, the Court of Appeals held that the trial court erred in not granting a new trial based on the improper invocation of inquiry notice by appellees’ counsel during rebuttal closing arguments. The court found that the trial court’s corrective instruction was insufficient to mitigate the prejudicial impact of the improper argument. Consequently, the case was remanded for a new trial. View "Ramey v. Foxhall Urology, Chartered" on Justia Law