Articles: Alabama

Mobile Infirmary Association v. Tyler (981 So.2d 1077)

CASE:

Mobile Infirmary Association v. Tyler (981 So.2d 1077)

PARTIES:

Plaintiff (Appellee) – Robert Tyler as administrator of the estate of his mother, Lida Mae Tyler

Defendant (Appellant) – Mobile Infirmary Association

COURT:

Supreme Court of Alabama, 2007

PROCEDURAL HISTORY:

Son, as administrator of his mother’s estate, filed a medical-malpractice and wrongful-death complaint against physicians, nurse, cardiology group, hospital, and others. The Circuit Court entered judgment on jury verdict against hospital, awarding estate $5,500,000 in damages. Hospital appealed.

SUMMARY OF FACTS:

Ms. Tyler was admitted to the hospital after experiencing an irregular heartbeat. Her treating physician checked her into the cardiac care unit where she was placed under the care of the Cardiac Associates of Mobile, P.C. (“CAM”) and put on intravenous medication and kept under observation. When Ms. Tyler’s original physician went offcallanother physician from CAM as well as a “triage nurse” took over Ms. Tyler’s care. Shortly thereafter, Ms. Tyler experienced extreme abdominal discomfort unlike anything she had experienced before. The treating on- site nurse contacted the triage nurse who was working from home. The triage nurse contacted the on- call CAM physician who instructed the nurse to proceed with the administration of medication. After Ms. Tyler’s abdominal discomfort worsened the on- call nurse again contacted the triage nurse who relayed the CAM physician’s instructions to order agastroenterologistconsult. Approximately 4 hours after the order was made, the consult occurred. At that time, the consultinggastroenterologist, based on his findings, ordered an ultrasound of Ms. Tyler’s gallbladder for the next morning. The next morning, prior to the ultrasound occurring, Ms. Tyler presented in extreme pain and was admitted to the intensive- care unit. There, Ms. Tyler’s original treating physician ordered emergency surgery. The surgery revealed that Ms. Tyler’s intestine was necrotic and she was suffering from an infection. The surgeon concluded that the necrosis was caused by amesentericblood clot and that the condition was fatal. Ms. Tyler died the next day.

OUTCOME AT TRIAL:

The jury found the hospital liable for medical- malpractice and wrongful- death, awarding Ms. Tyler’s estate $5,500,000 in damages.

ISSUES ON APPEAL:

1. Was there evidentiary support for the finding that the hospital nurse negligently failed to adequately and accurately communicate to medical group the nature and severity of Ms. Tyler’s abdominal pain?
2. Was there evidentiary support for finding that the hospital’s nurse’s failure to accurately report patient’s pain to physician’s medical group probably caused or contributed to Ms. Tyler’s death?
3. Was a reduction of punitive damages, based on statute, warranted?

SUPREME COURT HOLDINGS:

1. Yes.
2. Yes.
3. Yes.

RELEVANT APPLICATION OF LAW:

The Supreme Court of Alabama in this case upheld a reduction of the punitive damages awarded by the trial court. In so doing, they cited Section 6-11-21(d), Ala.Code 1975:”…in all civil actions for physical injury wherein entitlement to punitive damages shall have been established under applicable laws, no award of punitive damages shall exceed three times the compensatory damages or one million five hundred thousand dollars ($1,500,000), whichever is greater.”