Welsh v. Bulger

CASTILLE, Justice,

concurring and dissenting.

I concur with the majority’s holding that a plaintiff must present expert testimony in order to establish a prima facie case of corporate liability against a hospital pursuant to Thompson v. Nason Hospital, 527 Pa. 330, 591 A.2d 703 (1991), unless the hospital’s negligence is obvious. I nevertheless dissent here because I believe that the plaintiff/appellant has failed to present sufficient expert evidence for purposes of surviving summary judgment on the corporate liability claims asserted against appellee, Nason Hospital.

Initially, I note that like the majority, I believe that appellant suffered a tragic loss when her son died approximately eleven months after he was born. Also, I agree with the majority’s statement that experts are not required to use “magic words” when expressing their opinions. However, in order for appellant to defeat Nason Hospital’s motion for summary judgment, appellant must still produce a proper expert report to support her two claims of corporate liability. My review of appellant’s two corporate liability claims and her three expert reports leads me to the conclusion that appellant has not presented sufficient evidence to defeat Nason Hospital’s motion for summary judgment on either of the two claims of corporate liability.

Appellant first claims that when viewing her expert reports as a whole and in a light most favorable to her case, a material issue of fact exists as to her theory of negligence that Nason Hospital is corporately liable because its employees did not recognize and report the abnormalities in the delivery of appellant’s child to the hospital so that Nason Hospital could *517have taken the appropriate action to prevent the harm suffered. A prima facie case for this claim of corporate liability involves a showing that a hospital employee had a duty to recognize and report abnormalities in the treatment of a patient, that the hospital employee should have informed the attending physician of the abnormality and that the hospital employee should have informed the hospital of the abnormality when the attending physician failed to act so that the hospital could have taken corrective action. Thompson, 527 Pa. at 342-43, 591 A.2d at 709.

In this case, appellant presented three expert reports to support her theories of liability. The two expert reports of Warren E. Cohen, M.D. and Marshall Klaven, M.D. were not critical in any way of the hospital or its personnel for failing to obtain a surgical consult. However, the expert report of Dr. Warner stated that “the nurses must have known what was going on ... If Dr. Bulger had arranged for an appropriate cesarian section or the hospital had arranged for an appropriate cesarian section with the nurses’ input on this, there is every reason to believe that Kyle Allan Welsh would be an absolutely normal child today.”

The majority here seizes upon the words that the “nurses should have known what was going on” to establish that the nurses had a duty to recognize the problem, inform Dr. Bulger of the problem and that they should have informed the hospital of Dr. Bulger’s failure to act so that the hospital could have arranged a cesarian section and avoided the injury. I believe that such a reading of appellant’s expert report strains itself beyond viewing the evidence in a light most favorable to appellant in order to conclude that appellant’s expert report created a prima facie case of corporate liability.

Instead, I believe that when appellant’s expert report is viewed in a light most favorable to appellant as the non-moving party, the bare allegation of Dr. Warner that the hospital nurses “must have known” a problem had arisen is simply insufficient since it fails to elucidate the proper standard of care the hospital and its nurses owed to appellant, how the hospital and its nurses breached this duty by failing to *518recognize that Dr. Bulger’s actions were so far removed from acceptable medical practice that the hospital authorities should have been informed, and how this breach caused the harm suffered by appellant. See Mitzelfelt v. Kamrin, 526 Pa. 54, 62, 584 A.2d 888, 891 (plaintiff in medical malpractice required to produce medical expert who will testify to a reasonable degree of medical certainty that physician’s acts deviated from the appropriate standard of care and the deviation was the cause of the injury); Menarde v. Philadelphia Transportation Co., 376 Pa. 497, 501, 103 A.2d 681, 684 (1954) (expert must testify that in his professional opinion that the result in question came from the cause alleged by plaintiff; “[A] less direct expression of opinion falls below the required standard of proof and does not constitute legally competent evidence”). Because these omissions in appellant’s expert reports go beyond the mere failure to use “magic words,” I conclude that appellant, who bears the burden of proof at trial, has failed to produce evidence of facts essential as a matter of law to establish a prima facie case of corporate negligence against Nason Hospital under Thompson. Accordingly, I would affirm the Superior Court’s order affirming the entry of summary judgement in favor of Nason Hospital based on this particular assertion of corporate negligence.

Appellant’s second claim is that her expert reports create a material issue of fact as to her theory that Nason Hospital is corporately liable for granting obstetrical privileges to Dr. Bulger without limiting the exercise of his privileges to circumstances where surgical expertise was readily available in the event that surgery was needed. Like the previous claim of corporate liability, the majority holds that a reading of Dr. Warner’s expert report in a light most favorable to appellant is sufficient to establish a prima facie case of corporate liability concerning the failure to limit Dr. Bulger’s obstetrical privileges to circumstances where surgical expertise was available in case of complications. In particular, the majority finds that Dr. Warner’s expert report, which stated that if “the hospital had arranged for an appropriate cesarian section with the nurses’ input on this, there is every reason to believe that *519Kyle Allan Welsh would be an absolutely normal child today,” is sufficient to establish that the hospital had a duty to have a policy requiring a surgical consultant to be available where obstetrical privileges are limited and that the hospital’s failure to either have or follow such a policy resulted in the child’s death. Once again, I believe the majority strains itself beyond viewing the evidence in a light most favorable to appellant in order to conclude that appellant presented sufficient expert evidence to support this theory of corporate liability.

Here, the evidence clearly shows that Dr. Bulger was not qualified to perform surgery and that Nason Hospital did not grant Dr. Bulger surgical privileges. However, none of the expert evidence presented suggested that Nason Hospital was negligent in granting Dr. Bulger privileges because he was generally incompetent. Instead, the expert reports state that Dr. Bulger departed from acceptable medical practice by choosing not to undertake a surgical consult and a surgical delivery. Also, none of appellant’s expert reports set forth what standard of care Nason Hospital owed to its patients by not having another physician available to provide a consult, whether it was reasonable for a hospital to have such a policy in place requiring a physician with Dr. Bulger’s limited obstetrical privileges to consult with a surgeon about whether to perform a cesarian section and whether Nason Hospital should have known that such a policy was necessary to comply with a reasonable standard in conducting the hospital’s functions. Moreover, appellant’s expert reports, even when read in a light most favorable to appellant, fail to opine that the hospital’s failure to either have or to follow such a policy was the proximate cause of the injuries suffered. Thus, by these omissions in appellant’s expert reports, I conclude that appellant fails in her burden to establish a prima facie case of corporate negligence against Nason Hospital. Therefore, I would also affirm the Superior Court’s order affirming the trial court’s entry of summary judgment in favor of Nason Hospital on this issue.

Accordingly, while I agree that expert testimony is necessary to establish a prima facie case of corporate liability *520against a hospital, I believe that the expert testimony offered by appellant in this case was insufficient to defeat Nason Hospital’s motion for summary judgment. Therefore, I must respectfully dissent from the majority’s reversal of the Superi- or Court’s affirmance of the Blair County Court of Common Pleas order granting summary judgment in favor of Nason Hospital.