Beebe Medical Center, Inc. v. Bailey (913 A.2d 543)
- Beebe Medical Center, Inc. v. Bailey (913 A.2d 543)
Plaintiff (Appellee) – Bailey, as Administratrix of the Estate of Julie Bailey (Deceased)Defendant (Appellant) – Beebe Medical Center, Inc.
- Supreme Court of Delaware (2006)
- PROCEDURAL HISTORY:
- The estate of Julie Bailey sued Beebe Medical Center, a nursing home, asserting claims for pain and suffering and punitive damages under wrongful death statute. The parties settled on the punitive damages issue and the trial court found for the plaintiff on the remaining claims. Beebe appealed.
- SUMMARY OF FACTS:
- Julie Bailey was 60 years old and suffered from Alzheimer’s disease. Because of her disease, she functioned at the intellectual level of a two- year- old. On December 25, 2002, Julie suffered from stomach problems and went to Beebe for treatment. On December 28, 2002, Beebe transferred Julie to LCC, a nursing care facility that was owned by Beebe. Julie arrived to LCC around 11:00am, and approximately four to five hours later, LCC’s staff discovered that Julie was missing. After searching the facility for about four and a half hours, Julie was found locked in a freezer room in the facility’s kitchen. Julie was frozen to the floor by her own urine. She suffered severe frostbite and other injuries to her hands, feet and nose. Beebe treated Julie’s injuries, but failed to provide pain medication prior to administering the treatment. On January 21, 2003, Julie suffered a pulmonary embolism, and died shortly after.
On April 11, 2003, Bailey’s estate filed an action against Beebe asserting claims for pain and suffering and punitive damages related to Beebe’s negligent treatment of Julie. Julie’s surviving family members individually sought damages under Delaware’s Wrongful Death Statute.
In pre- trial motions, Beebe moved to have the trial trifurcated to separate (1) the estate’s claim, (2) the wrongful death claim, and (3) the punitive damages claim.
- OUTCOME AT TRIAL:
- The trial judge denied Beebe’s motion and the case went to trial on March 9, 2005. On March 15, after evidence had already been submitted the parties settled the punitive damages claim. On March 16 the trial resumed on the remaining two claims and the jury returned a verdict for compensatory damages of $4,000,000 for Julie Bailey’s estate, $3,000,000 to her husband, and $2,000,000 to each of her three sons, for a total of $13,000,000.
Beebe filed a motion for a new trial which was denied. Beebe then appealed the trial court’s decision.
- ISSUES ON APPEAL:
- 1) Did the judge abuse his discretion by denying Beebe’s motion for separate trials?2) Did Beebe waive their argument that the trial judge erred by not narrowing the scope of mental anguish for the compensatory damages claim?
3) Were the trial judge’s jury instructions relating to the punitive damages claim having been settled sufficient (so not to cause plain error)?
- SUPREME COURT HOLDINGS:
- 1) No
- RELEVANT APPLICATION OF LAW:
- Delaware law provides that when a person dies as a result of another’s wrongful act, certain family members may recover fair compensation for their losses resulting from the death. Mental anguish may be considered when determining fair compensation.