Fierle v. Perez

Pickering, J.,

concurring in part and dissenting in part:

The majority concludes that the affidavit requirement in NRS 41A.071 applies to a physician’s medical corporation and nurse. While I agree with the result, I respectfully disagree with the reasoning used to reach it. “Medical malpractice” is a type of “professional negligence,” such that the “professional negligence” statutes apply to “medical malpractice.” However, I submit that the syllogism does not run in reverse, such that the statutes specific to “medical malpractice” apply to all types of “professional negligence.” The majority’s contrary holding disregards settled rules of statutory construction and goes further than is needed to decide this appeal, with potentially disruptive consequences.

I also question the disposition of the res ipsa loquitur claims. If the Fierles’ unintended chemical burn claims qualify under Szydel v. Markman, 121 Nev. 453, 117 P.3d 200 (2005), and NRS 41A.100(1)(c), as res ipsa loquitur claims that do not need a supporting expert affidavit under NRS 41A.071, there does not appear to be a sound basis to distinguish between the actor (Nurse Mitchell) *742and the person with the legal duty to supervise the actor (Dr. Perez) in regard to them. Either we continue to adhere to Szydel, or we don’t, but we confuse things by applying the res ipsa loquitur doctrine halfway.

NRS 41 A.071 applies to this “medical malpractice” case but not to all “professional negligence” claims

NRS 41A.071 imposes its affidavit requirement only on “an action for medical malpractice.”1 The phrase “medical malpractice” is defined in NRS 41A.009 as “the failure of a physician, hospital or employee of a hospital, in rendering services, to use the reasonable care, skill or knowledge ordinarily used under similar circumstances.” “Hospital” is not defined in Chapter 41A but “physician” is, as “a person licensed pursuant to chapter 630 or 633 of NRS.” NRS 41A.013.

In contrast, the provisions respecting “professional negligence” by “provider[s] of health care” that were added to Chapter 41A in 2004 include, but cover more than, “medical malpractice.” Thus, NRS 41A.015 defines “professional negligence” as “a negligent act or omission to act by a provider of health care in the rendering of professional services.” “Provider of health care” includes not just “a physician licensed under chapter 630 or 633 of NRS” and a “hospital and its employees,” NRS 41A.017; see NRS 41A.009, but also a “dentist, licensed nurse, dispensing optician, optometrist, registered physical therapist, podiatric physician, licensed psychologist, chiropractor, doctor of Oriental medicine, [and a] medical laboratory director or technician.” NRS 41A.017. Unlike the affidavit requirement in NRS 41A.071, which only addresses actions for “medical malpractice” (or “dental malpractice”), the 2004 amendments to NRS Chapter 41A added multiple provisions that, by their terms, apply to all “professional negligence” claims against a range of “providers] of health care,” including but not limited to limits on noneconomic damages, NRS 41A.035, abolition of joint and several liability, NRS 41A.045, and special statute of limitations and tolling rules. NRS 41A.097.

The majority holds that the affidavit requirement in NRS 41A.071 “requires the attachment of expert affidavits for professional negligence claims,” as defined in NRS 41A.015, against all “provider[s] of health care,” as defined in NRS 41A.017. Ante at 738. This holding proceeds from the premise that the 2004 amendments to NRS Chapter 41A created a statutory “ambiguity.” Id. at 737. Specifically, the majority finds it inconsistent with the “intent” of the 2004 amendments to Chapter 41A for NRS 41A.071 to only apply to “medical malpractice” and not to “professional negligence” by *743“providers of health care” generally. Id. at 737-38. Thus, under the majority’s interpretation, a plaintiff wishing to sue a “dispensing optician, optometrist, [or] registered physical therapist,” NRS 41A.017, must obtain the expert affidavit NRS 41A.071 requires in “medical malpractice” actions.2

“It is an elementary rule of construction that effect must be given, if possible, to every word, clause and sentence of a statute ... so that no part will be inoperative or superfluous, void or insignificant . . . .” Norman J. Singer and J.D. Shambie Singer, 2A Sutherland Statutory Construction § 46:6, at 230-42 (7th ed. 2007) (internal quotation omitted). While the 2004 amendments to NRS Chapter 41A could have replaced “medical malpractice” with “professional negligence” everywhere the former appeared, this change wasn’t made; the medical malpractice-specific statutes were left intact. This leaves us to interpret “[t]he unchanged sections [of the original statute] and the amendment ... so they do not conflict. All the provisions of both are given effect and reconciled, if possible.” 1A id. § 22:35, at 404-05. Applying these rules of statutory construction, I respectfully submit that NRS 41A.071’s affidavit requirement should be read as limited to “medical malpractice” (or “dental malpractice”) actions rather than expanded judicially to apply to all “professional negligence” cases.

This said, I agree with the majority that the affidavit requirement in NRS 41A.071 applies to the defendant professional corporation, nurse, and nurse practitioner in this case. In her complaint, Ms. Fierle alleges she was burned as a result of the negligent administration of the chemotherapeutic agent epirubicin, injected by a nurse trained and supervised by Dr. Perez. This drug could not have been administered except by or under the supervision of a physician. NRS 630.369(l)(c).3 While the “services” may not have been personally provided by a ‘ ‘physician’ ’ but rather by a nurse acting *744under a physician’s supervision, the statute defining “medical malpractice,” NRS 41A.009, speaks in terms of “the failure of a physician, ... in rendering services, to use . . . reasonable care, skill or knowledge,” (emphasis added), focusing on the nature of the services rendered and their relationship to a physician, not the agent or agents who may physically assist the physician in rendering service. Since the injection Ms. Fierle received bears a substantial relationship to the rendition of medical treatment by a licensed physician, Dr. Perez, I would hold that this action qualifies as an “action for medical malpractice,” to which NRS 41A.071’s affidavit requirement applies, even as to his entity and assisting nurse. Other courts, confronted with similar statutes, have so held, and I would follow their lead here, avoiding the expansive statutory interpretation the majority pursues. See Potter v. McLeary, 774 N.W.2d 1 (Mich. 2009) (applying affidavit-of-merit requirement to physician’s corporate entity as well as physician); Gunter v. Laboratory Corp. of America, 121 S.W.3d 636, 640 (Tenn. 2003) (noting that “the medical malpractice statute may extend to acts of non-physicians such as nurses, when they are involved in the medical treatment of a patient”), discussed in Ward v. Glover, 206 S.W.3d 17, 25-27 (Tenn. Ct. App. 2006) (noting that the test for whether the medical malpractice statute applies is whether the “allegations describe conduct which constitutes or bears a substantial relationship to the rendition of medical treatment by a medical professional’ ’ (internal quotation omitted)); cf. Bleiler v. Bodnar, 479 N.E.2d 230, 234 (N.Y. 1985) (noting that nurses provide sophisticated medical care and that, while “not every negligent act of a nurse would be medical malpractice, ... a negligent act or omission by a nurse that constitutes medical treatment or bears a substantial relationship to the rendition of medical treatment by a licensed physician constitutes malpractice”).

Res ipsa loquitur

Negligence by a nurse performing services ultimately under a physician’s supervision or control is a classic example of a situation in which both the actor (the nurse) and another with a legal duty to the patient (the physician) can be subject to res ipsa loquitur:

A undergoes an operation. B, the surgeon performing the operation, leaves it to C, a nurse, to count the sponges used in the course of it. B is under a legal duty to A to exercise reasonable care to supervise the conduct of C in this task. After the operation a sponge is left in [A]’s abdomen. It can be inferred [by application of res ipsa loquitur] that this is due to the negligence of both B and C.

Restatement (Second) of Torts § 328D cmt. g, illus. 9 (1965). These are almost SzydeVs facts, and the rule of law they illustrate requires *745reversal as to both the doctor and the nurse, if Syzdel applies. Since the injection of the prescription-only chemotherapeutic agent necessarily occurred under the physician’s supervision, NRS 630.369, remand as to the nurse requires remand as to both the physician and the nurse under traditional res ipsa doctrine. Compare S. Speiser, 2 Res Ipsa Loquitur § 24:6, at 211 (1972) (noting that “the presence of multiple defendants in a medical malpractice action does not, of itself, render the doctrine of res ipsa loquitur inapplicable”), with Restatement (Second) of Torts § 328D cmt. g (noting that “[t]he essential question” in determining whether the res ipsa doctrine applies against multiple defendants is whether “the probable cause is one which the defendant was under a duty to the plaintiff to anticipate or guard against”).

The dissent in Szydel, 121 Nev. 453, 117 P.3d 200, and a plain reading of NRS 41A.071 and NRS 41 A. 100, persuade me that NRS 41A.071’s affidavit requirement should apply to all medical malpractice actions, without regard to whether one of the res ipsa loquitur exceptions in NRS 41 A. 100(1) might ultimately apply at trial. However, SzydeVs interpretation of the relationship between NRS 41A.071 and NRS 41A.100 is on the books, and the Fierles relied on it in this case, making it unfair to change the rules mid-game. But even though Szydel dispenses with NRS 41A.071’s initial affidavit requirement as to the Fierles’ allegations of an unintended chemical burn, the decision does not relieve the Fierles of their burden to qualify their burn claims legally and factually under NRS 41A.100(1)(c). Szydel, 121 Nev. at 460 n.32, 117 P.3d at 205 n.32; Restatement (Second) of Torts § 328D cmt. g (noting that in multiple defendant res ipsa cases the plaintiff must demonstrate “that the defendant is responsible for all reasonably probable causes to which the event can be attributed”). Given that the negligence may have been that of the surgeon who inserted Ms. Fierle’s port, or some other person or agency, that burden may well prove unsustainable and certainly will require expert proof to substantiate. These problems will require resolution on remand and illustrate the difficulties with Szydel that may ultimately require its legislative or judicial limitation.

NRS 41A.071 also applies to “dental malpractice,” but this aspect of the statute is not involved in this case.

Other medical malpractice-specific statutes that were unchanged by the 2004 amendments to NRS Chapter 41A include NRS 41A.061 (time to trial), NRS 41A.081 (mandatory settlement conferences), and NRS 41A.085 (settlement).

Entitled “[i]njecting patient with certain chemotherapeutic agents,” NRS 630.369 was added to the NRS in 2007. This statute provides that

[a]person, other than a physician, shall not inject a patient with any chemotherapeutic agent classified as a prescription drug unless:
(a) The person is licensed or certified to perform medical services pursuant to this title [54];
(b) The administration of the injection is within the scope of the person’s license or certificate; and
(c) The person administers the injection under the supervision of a physician.

NRS 630.369(1). Although enacted after Ms. Fierle’s treatment, this statute appears to declare professional standards, not to impose new ones, and thus may be fairly consulted, certainly at the pleading stage.