BRANDY EVANS v. THE MEDICAL CENTER OF CENTRAL GEORGIA D/B/A THE MEDICAL CENTER, A21A0256

Background

On July 26, 2014, Ralph Moss presented to the Medical Center of Central Georgia ED with chest pain and vomiting; Nurse Briana Stelmachers performed a single ECG (prelim: "Borderline") and one troponin (0.09 ng/mL, slightly elevated).
ED physician Dr. Nathan Stokes reviewed the ECG as showing "no ischemic changes," evaluated Moss, and discharged him at 2:42 p.m. after one ECG/troponin; hospital protocol used "track" order-sets that could require serial ECGs/troponins for suspected cardiac cases, but no formal track was assigned.
Moss died the next day at home from an acute myocardial infarction. Plaintiff (Evans, substituted as administrator) sued for medical malpractice; claims against Drs. Stokes and Panchapakesan were resolved, leaving Nurse Stelmachers and MCCG as defendants.
Plaintiff’s experts (an RN and a cardiologist) opined that Stelmachers breached the standard of care by inadequate triage, failing to complete/communicate the triage form, not advocating for a track or serial testing, and that those breaches contributed to a premature discharge that "almost certainly" led to death.
Defendants moved for summary judgment; the trial court granted it, finding no genuine issue that Stelmachers’s conduct proximately caused Moss’s death because Dr. Stokes would have discharged Moss regardless.
The Court of Appeals reversed, holding that expert testimony created a triable issue on proximate causation and distinguishing prior cases relied on by defendants.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether summary judgment was proper because there is no genuine issue that the nurse's negligence did not proximately cause death	Nurse breached standards (triage level, incomplete form, failure to ensure track/advocate for serial testing); expert testimony ties those breaches to a premature discharge that led to death	Dr. Stokes would have discharged Moss regardless; any nurse errors were not the proximate cause	Reversed: expert testimony (RN and MD) created a genuine issue whether nurse's breaches contributed to premature discharge and death; causation for jury to decide
Whether a registered nurse expert may testify about causation (identifying symptoms and whether nurse's failures caused discharge)	RN expert may testify as to symptom identification, triage practice, and whether nursing breaches caused or contributed to discharge	Defendants contend only a physician may opine on causation	Court accepted RN expert testimony on issues within her expertise, when coupled with a physician expert, as sufficient to raise a jury question
Whether this case is controlled by Swint or Reeves such that summary judgment is required	This case is distinguishable: evidence links premature discharge to death and shows nurse could have affected care (serial testing/advocacy)	Defendants relied on Swint/Reeves to argue causation was too speculative or that proper diagnosis would not have changed outcome	Court distinguished both cases and found they did not control; genuine factual disputes remain

Key Cases Cited

Knight v. Roberts, 316 Ga. App. 599 (malpractice requires proof of breach and proximate cause)
Central Ga. Women’s Health Ctr., LLC v. Dean, 342 Ga. App. 127 (proximate causation in malpractice requires expert proof and is usually for the jury)
Moore v. Singh, 326 Ga. App. 805 (questions of causation are for the jury except in clear, undisputed cases)
Peach Blossom Dev. Co. v. Lowe Elec. Supply Co., 300 Ga. App. 268 (summary judgment improper if opposing party produces any specific evidence raising a triable fact)
Swint v. Mae, 340 Ga. App. 480 (distinguished; example where causation was too uncertain for liability)
Reeves v. Mahathre, 328 Ga. App. 546 (distinguished; missed diagnosis would not have changed treatment, so no causation)
Freeman v. LTC Healthcare of Statesboro, Inc., 329 Ga. App. 763 (RN may testify as an expert on matters within her nursing expertise)