Rheaetta F. Wilson v. Americare Systems, Inc., 397 S.W.3d 552

Ms. Farrar, an elderly resident of Celebration Way, died from a perforated colon after a fatal enema following chronic constipation.
She was prescribed MiraLAX daily, but Celebration Way staff administered it inconsistently, allegedly contributing to constipation and fecal impaction.
Dr. Tamula ordered multiple daily enemas; on May 27 and May 29, 2004, enema administration occurred under conditions the medical experts deemed improper.
The facility personnel reportedly failed to notify the doctor of constipation, chart care, or follow dosing and order changes, while Americare provided management services.
The trial court entered a 21-item directed verdict finding several deviations from standard care; the jury allocated fault (Americare 50%, Steelman 30%, Hunt 20%) and awarded damages and punitive damages.
The Court of Appeals reversed, holding there was no material evidence Americare’s staffing caused Farrar’s death; the Tennessee Supreme Court reversed the Court of Appeals and reinstated the verdict.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was staffing deficiency a substantial factor in Farrar’s death?	Wilson/Wilson argue understaffing causally contributed to death.	Americare contends no material evidence links staffing to death.	Yes; material evidence supports causation.
Did the Plaintiffs prove causation in fact and proximate causation?	Plaintiffs contend multiple care failures caused death.	Americare asserts causation not established beyond speculation.	Causation in fact and proximate causation shown by the record.
Was expert testimony required to prove the standard of care for staffing?	Plaintiffs relied on medical and nursing expert testimony.	Americare argues no expert testimony needed for staffing standard.	The record supports adequate proof of staffing standards; expert proof not essential here.
Did the jury verdict on punitive damages have sufficient evidentiary support?	Punitive damages supported by clear and convincing evidence of gross negligence.	Americare challenges punitive damages magnitude and basis.	Remand for review of punitive damages; statutory standard applied.

Hale v. Ostrow, 166 S.W.3d 713 (Tenn. 2005) (causation standards and jury questions)
Barkes v. River Park Hosp., Inc., 328 S.W.3d 829 (Tenn. 2010) (material-evidence standard for reversing verdicts)
McClenahan v. Cooley, 806 S.W.2d 767 (Tenn. 1991) (jury questions on causation and evidence)
Pullins v. Fentress Cnty. Gen. Hosp., 594 S.W.2d 663 (Tenn. 1979) (causation to be determined by jury when reasonable inferences exist)
Estate of French v. Stratford House, 333 S.W.3d 546 (Tenn. 2011) (understaffing evidence considered by juries in care settings)
Conaway v. N.Y. Life Ins. Co., 102 S.W.2d 66 (Tenn. 1937) (jury may infer facts from circumstantial evidence)