Elias B. & Ana-lillia Langholt, V. Kaiser Foundation Health Plan, 85223-0

In Aug 2022 Elias Langholt, who had balance problems, was placed on a gurney at Kaiser Urgent Care with siderails down, slipped off, and struck his head; he immediately reported hip, shoulder, and head pain.
Imaging documented a displaced acromion (shoulder) fracture; records did not document hip or head injuries. Siderails were raised after the fall.
Langholt sued Kaiser for medical negligence and lack of informed consent; Elias later died and plaintiffs alleged the head injury contributed to death.
Kaiser moved for summary judgment contending plaintiffs lacked a qualified medical expert to prove standard of care and causation; Kaiser also noted the death certificate listed lymphoma as cause of death.
Plaintiffs submitted declarations from Linda Fordham, an experienced registered nurse (CV later attached), who opined siderails should have been raised and that the fall likely caused the alleged injuries.
The trial court granted summary judgment dismissing all claims with prejudice; on appeal the court affirmed dismissal of claims for hip, head, death, and informed consent, but reversed as to the shoulder claim and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Expert competency	Fordham, an RN with decades of experience, is a qualified expert to establish standard of care and causation.	Fordham lacks necessary qualifications and specificity to opine on all alleged injuries.	Fordham is qualified to testify about nursing standard of care and the documented shoulder injury, but not qualified to opine on undocumented/undiagnosed head or hip injuries.
Causation for shoulder injury	The fall from the gurney caused the acromion fracture; Fordham links failure to raise siderails to that injury.	Shoulder pain on admission could indicate the fracture preexisted the fall.	Causation is a genuine factual dispute; summary judgment reversed as to shoulder claim and remanded for merits.
Causation for head, hip, and resulting death	Plaintiffs maintain those injuries were caused by the fall and head injury caused death.	No documented head or hip injury in records; death certificate attributes death to lymphoma.	No competent expert evidence tying the fall to the undocumented head/hip injuries or to death; those claims affirmed dismissed.
Informed consent	Plaintiffs alleged acts were done without informed consent.	Plaintiffs failed to identify what information was omitted, which provider failed to obtain consent, or supply expert support.	Informed consent claim lacked factual or expert support and was properly dismissed.

Frausto v. Yakima HMA, LLC, 188 Wn.2d 227 (Wash. 2017) (nurses competent to testify about nursing standard but not to supplant physician standard)
Young v. Key Pharm., Inc., 112 Wn.2d 216 (Wash. 1989) (only physicians may testify as to another physician's standard of care)
Behr v. Anderson, 18 Wn. App. 2d 341 (Wash. App. 2021) (expert testimony generally required to establish standard of care and causation in medical negligence)
Guile v. Ballard Cmty. Hosp., 70 Wn. App. 18 (Wash. App. 1993) (plaintiff must produce affidavit from qualified expert alleging specific facts establishing causation)
Watness v. City of Seattle, 16 Wn. App. 2d 297 (Wash. App. 2021) (de novo review of evidentiary rulings made with a summary judgment motion)
Nichols v. Peterson NW, Inc., 197 Wn. App. 491 (Wash. App. 2016) (standard of review for summary judgment)