Trial Court’s Denial of Motion for JML and Motion for New Trial in Medical Malpractice Case Affirmed
Ansley v. Inmed Group, Inc. d/b/a Bullock County Hospital et al.
The administrator of James Ansley’s estate brought a wrongful death action against the entity that operates Bullock County Hospital, and the estate of Dr. Ireneo Domingo, Jr., the emergency room physician who originally treated the decedent. The complaint alleged that Ansley’s death was based on the Defendants’ medical malpractice. The jury returned a verdict in favor of "all defendants." The Bullock Circuit Court ("the trial court") entered a judgment on that verdict.
At the close of the evidence and prior to a verdict being rendered, t
he plaintiff, Alisa Ansley, administrator of the estate, filed a motion for partial judgment as a matter of law “on the issue of [Ansley’s] standard of care allegations regarding Dr. Domingo’s treatment in his capacity as a hospitalist.” Ansley did not argue that she was entitled to a JML on the issue of whether Dr. Domingo breached the standard of care or the issue of causation. The trial court denied the motion. Ansley subsequently filed a post-judgment motion for a new trial. The trial court denied the motion, and Ansley appealed.
The Supreme Court of Alabama affirmed. In her brief, Ansley suggested that she was entitled to a JML on all elements of her medical malpractice claim. However, Ansley moved for a JML only as to whether Dr. Domingo breached the applicable standard of care while allegedly acting as a hospitalist. Thus, the Supreme Court refused to allow Ansley to make that argument on appeal. Ansley argued that she was entitled to a new trial based on the trial court's alleged error in denying her motion for a JML on her claim that Dr. Domingo breached the standard of care applicable to a hospitalist. The Defendants argued that a jury question existed as to whether Dr. Domingo acted as a hospitalist. The Supreme Court agreed.
Ansley also argued that she was entitled to a new trial because the Defendants presented evidence of the Bullock County Hospital’s poor financial condition, which she argued was irrelevant. The trial court refused to allow her to present rebuttal evidence of BCH’s wealth. Ansley's primary theory of liability during the trial was that BCH did not have equipment capable of diagnosing the pulmonary embolism. The Supreme Court held that Ansley did not establish that the trial court exceeded its discretion in allowing the testimony regarding BCH’s resources or in refusing to allow Ansley to present evidence of BCH's alleged wealth.