Justia Medical Malpractice Opinion Summaries

The plaintiffs, Norene Rodríguez and Iris Rodríguez, sued Encompass Health Rehabilitation Hospital of San Juan, Inc. and Dr. José Báez Córdova for medical malpractice related to the treatment of their mother, Gloria Rodríguez González, who died after being treated for COVID-19. They alleged negligence in her care, particularly in failing to provide timely prophylactic medication for deep vein thrombosis, which they claimed led to her death.The United States District Court for the District of Puerto Rico granted summary judgment in favor of the defendants. The court concluded that the plaintiffs had not demonstrated any genuine issue of material fact and that the defendants were entitled to judgment as a matter of law. The court also found that Dr. Báez was immune from suit under Puerto Rico law, as he was acting within his duties as a faculty member of the University of Puerto Rico (UPR) at the time of the alleged malpractice. Consequently, Encompass could not be held vicariously liable for his actions. The plaintiffs' remaining claims were deemed waived for lack of development.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that Dr. Báez was immune from suit under Puerto Rico law, as he was acting in his capacity as a UPR faculty member supervising medical residents. The court also upheld the district court's application of the local anti-ferret rule, which disregarded certain facts not adequately supported by specific citations to the record. The plaintiffs' argument that Encompass was vicariously liable for the actions of other non-immune personnel was deemed waived, as it was not raised in the lower court. The appellate court found no abuse of discretion in the district court's denial of an evidentiary hearing. View "Rodriguez v. Encompass Health Rehabilitation Hospital of San Juan, Inc." on Justia Law

After Enrique Ojeda-Morales (Ojeda) died, his widow and his sister (collectively, Plaintiffs) filed a negligence action against two doctors, including Dr. Jorge Rodriguez-Wilson (Dr. Rodriguez), and related medical facilities. The medical facilities and one medical doctor (collectively, the settling parties) entered into settlement agreements with Plaintiffs. The district court dismissed the settling parties from the case, leaving Dr. Rodriguez as the sole defendant. After a trial, the jury concluded that Dr. Rodriguez’s negligent care was the proximate cause of Ojeda’s death and awarded Plaintiffs $475,000. The district court issued a judgment in favor of Plaintiffs. Dr. Rodriguez sought to alter the judgment, arguing that the jury’s damages award should be offset against the $700,000 that Plaintiffs received from the settling parties. The district court agreed and vacated the jury award. The First Circuit vacated the district court’s ruling, holding (1) the district court improperly vacated the jury award, as the district court misapplied Puerto Rico law when it implemented a dollar-for-dollar offset, and furthermore, Dr. Rodriguez waived any argument that he was entitled to offset; and (2) Dr. Rodriguez engaged in obstinate conduct trial trial, and therefore, the district court erred in refusing to grant Plaintiffs attorneys’ fees. View "Gomez v. Rodriguez-Wilson" on Justia Law

Plaintiffs filed a second amended complaint against Defendant, a medical doctor, alleging claims based on medical negligence, Defendant’s failure to obtain informed consent, and battery. The district court granted summary judgment in favor of Defendant as to the medical battery claim. After a trial as to Plaintiffs’ informed consent claim, the jury returned a verdict for Defendant. The First Circuit affirmed in part and vacated and remanded in part, holding (1) the district court properly dismissed Plaintiffs’ battery claim; but (2) the district court erred by excluding expert testimony that a fine-needle aspiration biopsy was a viable non-surgical alternative to a surgical biopsy. View "Bradley v. Sugarbaker" on Justia Law