Justia U.S. 1st Circuit Court of Appeals Opinion SummariesArticles Posted in Medical Malpractice
Gonzalez-Arroyo v. Doctors’ Center Hospital Bayamon, Inc.
The First Circuit affirmed the judgment of the district court granting the motion in limine and motion for summary judgment brought by Defendants, Doctors' Center Hospital Bayamon and Dr. Benito Hernandez-Diaz (together, the Hospital), holding that the district court did not err or abuse its discretion.Plaintiff brought a medical malpractice action on behalf of her child and against the Hospital claiming that the Hospital failed to treat the child's oxygen-loss at birth, causing him serious cognitive injury. At issue was the decision of the district court granting the Hospital's motion to strike Plaintiff's expert's report and testimony on the grounds that it was speculative and otherwise failed to conform to established rules for such reports. The First Circuit affirmed, holding that the district court (1) did not abuse its discretion in excluding the expert testimony was unreliable; (2) did not err in granting summary judgment for the Hospital; and (3) did not err in denying Plaintiff's motion for reconsideration. View "Gonzalez-Arroyo v. Doctors' Center Hospital Bayamon, Inc." on Justia Law
Oquendo-Lorenzo v. Hospital San Antonio, Inc.
The First Circuit affirmed the order of the district court entering judgment against Hospital San Antonio, Inc. (HSA) and denying HSA's subsequent motion for relief under Fed. R. Civ. P. 60(b), holding that the district court did not err or abuse its discretion in the challenged rulings.Plaintiffs brought a medical malpractice suit against Defendants, healthcare providers and their insurance carriers, alleging that the birth injuries suffered by their daughter and her subsequent death resulted from Defendants' negligence. The district court entered a partial judgment against defendant HSA and dismissed the claims against the remaining defendants. While its appeal was pending, HSA filed a motion for relief under Rule 60(b), which the district court denied. The First Circuit affirmed the final judgment of the district court and the denial of Plaintiffs' Rule 60(b) motion, holding that HSA did not benefit from the liability limits in P.R. Laws Ann. Tit. 32, 3077, which waives Puerto Rico's sovereign immunity and establishes liability caps in certain circumstances. View "Oquendo-Lorenzo v. Hospital San Antonio, Inc." on Justia Law
Kenyon v. Gonzalez-Del Rio
The First Circuit affirmed the decisions of the district court granting partial summary judgment to defendant-physicians and denying Plaintiffs' motion for reconsideration in light of the decision in Oquendo-Lorenzo v. Hospital San Antonio, Inc., 256 F. Supp. 3d 103 (D.P.R. 2017), holding that the district court did not err or abuse its discretion.Plaintiffs filed this suit on behalf of themselves, their conjugal partnership, and their minor daughter, C.A.K., alleging that Defendants breached their duty of care and departed from medical standards when treating C.A.K. in the emergency room of San Antonio Hospital. The district court granted partial summary judgment for Defendants, concluding that they were absolutely immune from liability for negligence under recent amendments to Article 41.050 of the Puerto Rico Insurance Code. After Oquendo-Lorenzo was subsequently decided, Plaintiffs moved for reconsideration. The district court denied the motion. The First Circuit affirmed the district court's judgment and order denying the motion to reconsider, holding that there was no error or abuse of discretion. View "Kenyon v. Gonzalez-Del Rio" on Justia Law
Martinez v. United States
The First Circuit reversed the order of the district court granting summary judgment against Plaintiffs in this medical malpractice suit brought under the Federal Tort Claims Act (FTCA), see 28 U.S.C. 1346(b), 2671-2680, holding that summary judgment was inappropriate.Noel Martinez-Marrero died while being treated at the United States Department of Veterans Affairs Medical Center. His four children brought suit against the United States in the District of Puerto Rico pursuant to the FTCA, alleging medical negligence. The district court granted summary judgment in favor of Defendants after excluding the expert testimony of Dr. Ortiz Feliciano. The First Circuit reversed and remanded the case for further proceedings, holding that the district court erred in excluding Dr. Feliciano's expert testimony pursuant to Fed. R. Evid. 702 and Fed. R. Civ. P. 26. View "Martinez v. United States" on Justia Law
Lopez-Ramirez v. Centro Medico del Turabo, Inc.
The First Circuit affirmed the grant of summary judgment against Eulalia Lopez-Ramirez (Lopez) in the medical malpractice suit that she and her daughter brought under Puerto Rico law, holding that Plaintiffs' allegations of error were unavailing.Plaintiffs brought this suit seeking damages in connection with the brain surgery that was performed on Lopez to alleviate her facial spasms. After the surgery, Lopez developed full right facial paralysis. Plaintiffs claimed that Defendants' negligence in providing medical care to Lopez made them liable under Puerto Rico Laws title 31, Section 5141 and 5142. The district court granted summary judgment for Defendants. The First Circuit affirmed, holding that Plaintiffs' allegations of error were unavailing. View "Lopez-Ramirez v. Centro Medico del Turabo, Inc." on Justia Law
Maldonado-Cabrera v. Anglero-Alfaro
The First Circuit vacated the order of the district court dismissing Plaintiffs' action seeking damages for medical malpractice, holding that the district court abused its discretion by failing to apply the requisite exceptional-circumstances test.Plaintiffs commenced this civil action in federal court alleging negligence under Puerto Rico law leading to the death of their mother. Approximately one month earlier, a larger group of plaintiffs brought a similar medical malpractice suit in the superior court of Puerto Rico also arising from the decedent's death. A defendant in both cases filed a motion in federal court to stay or dismiss the federal court proceeding. The district court granted the motion, finding the "prior pending action" doctrine applicable. The First Circuit vacated the order below, holding that the district court erred in applying the "prior pending action" doctrine in lieu of the test set forth in Colorado River Water Conservation District v. United States, 424 U.S. 800 (1976) and its progeny. View "Maldonado-Cabrera v. Anglero-Alfaro" on Justia Law
Rodriguez-Valentin v. Doctors’ Center Hospital (Manati), Inc.
In this medical malpractice action the First Circuit affirmed the judgment of the district court entering judgment in accordance with the jury's verdict finding Doctors' Center Hospital (Manati), Inc. (Doctors' Center) liable for eight percent of a more than $14 million total award, holding that there was no error.This lawsuit stemmed from obstetric care provided to Plaintiff, Jeanette Rodriguez-Valentin in connection with the birth of her son, DALR. The jury found Doctors' Center liability and awarded damages. The jury apportioned ninety-two percent of that liability to two treating physicians with whom Plaintiff settled prior to trial and apportioned to Doctors' Center the remaining amount of $1,143,680. The First Circuit affirmed, holding that the district court (1) did not err or abuse its discretion in deferring to the jury's evaluation of the evidence; and (2) did not err in denying Doctors' Center's motions for judgment as a matter of law, for a new trial, or for remittitur. View "Rodriguez-Valentin v. Doctors' Center Hospital (Manati), Inc." on Justia Law
Santos-Arrieta v. Hospital Del Maestro, Inc.
The First Circuit vacated the entry of an amended judgment entered in this medical malpractice case, holding that the district court erred in granting judgment as a matter of law.Plaintiffs, a couple and their minor child, sued Defendants, a hospital and a medical doctor, seeking damages for the brain damage that the child suffered at his birth. The jury entered a verdict of just under $5 million in favor of Plaintiffs. The hospital subsequently filed two post-trial motions - a renewed motion for judgment as a matter of law under Fed. R. Civ. P. 50(b). In granting the motion, the district court reconsidered its position at trial and struck the testimony of the only expert on future costs. The court then entered an amended judgment setting aside just over $3 million of the judgment. The First Circuit vacated the judgment below, holding that the district court erred. View "Santos-Arrieta v. Hospital Del Maestro, Inc." on Justia Law
Melendez-Colon v. Rosado-Sanchez
The First Circuit reversed the judgment of the district court dismissing and this medical malpractice claim, holding that the lawsuit was timely filed and not outside the statute of limitations.The district court set aside a jury verdict for Plaintiffs, granted Defendants' motion for judgment as a matter of law, and dismissed this case as untimely, finding that a reasonable jury could not have concluded that this suit was not time barred. On appeal, Plaintiffs argued that even with the exercise of proper diligence they could not have had the requisite knowledge to file suit against Defendant more than one year before they did. The First Circuit agreed and reversed, holding that a reasonable jury could have found that Plaintiffs did not obtain the necessary knowledge to sue until sometime after one year prior to filing suit. View "Melendez-Colon v. Rosado-Sanchez" on Justia Law
Morales-Figueroa v. Valdes, D.C.
The First Circuit affirmed in part and reversed in part the judgment of the district court taxing Appellant with costs related to expert witnesses used at a jury trial that Appellant lost in his medical malpractice suit against Appellees, holding that certain court costs exceeded the court's authority.After the verdict was rendered, the district court taxed Appellant with costs related to expert witnesses used at trial. On appeal, Appellant challenged the taxation of those costs. The First Circuit affirmed in part and reversed in part, holding (1) the district court's cost award with respect to Dr. LaRusso, Appellees' expert witness, exceeded the parameters of Crawford Fitting Co. v. J.T. Gibbons, Inc., 482 U.S. 437 (1987); and (2) the remainder of the district court's order on costs was appropriate. View "Morales-Figueroa v. Valdes, D.C." on Justia Law