Williams v. Booker
310 Ga. App. 209
| Ga. Ct. App. | 2011Background
- Medical malpractice suit against Williams (surgeon) and Meadows Regional Medical Center over Booker's bile duct injury from laparoscopic cholecystectomy in 2001.
- Booker alleged Williams was alcoholic and that addiction impaired his performance; hospital allegedly knew of addiction and failed to disclose it.
- Williams admitted alcoholism; relapse occurred mid-2000 to 2001; hospital learned of relapse June 19–22, 2001.
- Williams relapse involved heavy alcohol use at home; he contended he did not drink before surgery and had no patient responsibility during relapse period.
- Booker deposed hospital staff; no evidence showed Williams was visibly intoxicated during Booker's March–April 2001 treatment.
- Trial court denied partial summary judgment on alcohol addiction; the appeals court granted reversal on that issue.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does physician alcoholism at time of surgery create an independent negligence claim? | Booker asserts alcoholism alone is negligence. | Williams/Meadow argue addiction must translate to substandard care. | No independent claim; only relevance if linked to standard of care. |
| Admissibility of alcohol use evidence to prove impairment at surgery | Evidence of addiction admissible to show impairment. | No basis linking addiction to impairment at time of surgery; risk of prejudice. | Court abused discretion admitting addiction evidence without linkage to negligent conduct. |
| Hospital's duty to inform patient of physician's alcoholism | Hospital had duty to disclose physician's addiction to patient. | No legal duty to disclose; physician disclosure is primary; hospital not obligated. | No duty to disclose; failure to inform claim fails. |
Key Cases Cited
- Ornelas v. Fry, 151 Ariz. 324 (Ariz. 1986) (alcoholism must translate into below-standard conduct to matter)
- Watson v. Chapman, 343 S.C. 471 (S.C. 2000) (alcohol/drug use evidence admissible only if tied to impairment at time of treatment)
- Wheeler v. Stewart, 234 Ga.App. 714 (Ga. App. 1998) (relevance of physician's alcohol use; admissibility concerns)
- Whorton v. Boatwright, 233 Ga. App. 369 (Ga. App. 1998) (limits on admitting past alcohol use; relevance required)
- Albany Urology Clinic, P.C. v. Cleveland, 272 Ga. 296 (Ga. 2000) (no duty to disclose drug use; informed-consent context)