McHale, P. v. Riddle Memorial Hospital, 3749 EDA 2016

Background

Plaintiff Patrick J. McHale, III (executor and in his own right) sued Riddle Memorial Hospital / Main Line Health after his mother (Decedent) was found on the ground in a hospital parking garage following a cardiac rehab visit; Decedent fell into a coma and died without eyewitnesses to the fall.
Plaintiff alleged Decedent tripped over an unpainted, 5.5-inch concrete parking bumper (wheel stop) while walking from a handicap-designated walkway to her car and offered an expert report supporting that theory.
Defendants moved for summary judgment; the trial court granted summary judgment for RMH/MLH, finding plaintiff failed to adduce evidence that the alleged parking bumper/walkway defects caused the fall (causation).
The Superior Court initially quashed an earlier appeal as nonfinal because one defendant remained; plaintiff discontinued that remaining claim and reappealed.
On appeal the Superior Court affirmed summary judgment, holding the record lacked sufficient direct or circumstantial evidence to permit a jury to infer the hospital’s alleged defects proximately caused Decedent’s fall.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Did trial court apply proper standard for summary judgment?	Trial court failed to apply the correct deference and should have drawn favorable inferences for plaintiff.	Court applied summary judgment standard and resolved doubts for nonmoving party; no error.	Held: No reversible error in standard application.
2. Was there sufficient direct or circumstantial evidence of breach and causation to send to a jury?	Expert and circumstantial facts (unpainted bumpers, noncompliant walkway, Decedent’s statements) support a reasonable inference that she tripped on a wheel stop.	Evidence only shows an accident occurred; no proof Decedent used the defective path or tripped over a particular bumper—causation speculative.	Held: Insufficient evidence of causation; summary judgment proper.
3. Did the court improperly substitute its own factual version/usurp the jury?	Trial court substituted its view of facts instead of allowing jury to choose among inferences.	The record is too meager—allowing jury would require speculation; court appropriately resolved legal sufficiency.	Held: No usurpation; judge properly concluded no rational basis for jury to prefer plaintiff’s theory.
4. Were Decedent’s statements to medical personnel admissible as substantive evidence?	Decedent’s repeated statements identifying a “trip over a curb/parking bumper” are substantive and support causation.	Even if admissible, the statements do not establish location, path, or why she tripped; they are insufficient to prove causation.	Held: Court did not reach this issue as dispositive causation finding resolved the appeal.

Key Cases Cited

Truax v. Roulhac, 126 A.3d 991 (Pa. Super. 2015) (summary judgment standard and appellate review).
Helpin v. Trustees of Univ. of Pennsylvania, 969 A.2d 601 (Pa. Super. 2009) (expert opinion must be grounded in adequate factual basis; mere possibilities are incompetent).
Lux v. Gerald E. Ort Trucking, Inc., 887 A.2d 1281 (Pa. Super. 2005) (proximate cause is required element; court addresses proximate cause as a legal question).
First v. Zem Zem Temple, 686 A.2d 18 (Pa. Super. 1996) (circumstantial evidence may permit jury inference of causation where record supports a rational basis).
Cade v. McDanel, 679 A.2d 1266 (Pa. Super. 1996) (limits on withdrawing close cases from jury; standards for circumstantial evidence).
Smith v. Bell Telephone Co. of Pennsylvania, 153 A.2d 477 (Pa. 1959) (discussing burden when relying on circumstantial evidence and jury rights).