Snyder, B. & T. v. Mount Nittany Medical Center
Snyder, B. & T. v. Mount Nittany Medical Center No. 1545 MDA 2016
| Pa. Super. Ct. | May 26, 2017Background
- Bernadette and Travis Snyder filed pro se a medical malpractice suit after Bernadette suffered an amniotic fluid embolism and subsequent complications following a C-section on March 1, 2013.
- Dr. Feffer placed a right internal jugular central line; Geisinger later found the line malpositioned, removed it, and stabilized Bernadette.
- Snyders alleged the misplaced central line, failure to recognize it, and inability to control bleeding caused additional harm, including prolonged intubation.
- Trial court ordered expert reports by May 15, 2016; defendants produced two expert reports finding no deviation from the standard of care; the Snyders produced none and indicated none would be forthcoming.
- Defendants moved for summary judgment; the court granted it for lack of expert proof on negligence, and the Snyders appealed, arguing res ipsa loquitur should apply.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether res ipsa loquitur removes the need for expert testimony | Res ipsa applies because the misplaced central line and resulting harm "speak for themselves" | Complex medical questions (line placement, detection, causation) are beyond lay understanding and require expert proof | Court held res ipsa did not apply; expert testimony was required and none was produced, so summary judgment proper |
| Whether absence of plaintiff expert eliminates a prima facie case | Snyders argued res ipsa creates an inference of negligence eliminating need for expert | Defendants argued plaintiff bears burden to prove duty, breach, causation and must present expert absent obvious negligence | Court held plaintiff failed to meet burden; no expert = no prima facie case |
Key Cases Cited
- Truax v. Roulhac, 126 A.3d 991 (Pa. Super. 2015) (standard of review and summary judgment principles)
- Fessenden v. Robert Packer Hosp., 97 A.3d 1225 (Pa. Super. 2014) (medical malpractice elements and expert-testimony requirement; obvious errors exception)
- Jones v. Harrisburg Polyclinic Hosp., 437 A.2d 1134 (Pa. 1981) (res ipsa loquitur applied where nerve injury was not ordinarily caused absent negligence)
- Quinby v. Plumsteadville Family Practice, Inc., 907 A.2d 1061 (Pa. 2006) (res ipsa warranted where an unattended patient fell during care)
- MacNutt v. Temple Univ. Hosp., Inc., 932 A.2d 980 (Pa. Super. 2007) (res ipsa inapplicable for complex surgical injury where expert proof required)