Wallace v. St. Francis Hospital & Medical Center
In Wallace v. St. Francis Hospital & Medical Center, 44 Conn. App. 257, 688 A.2d 352 (1997), the plaintiff, the administratrix of the decedent's estate, brought a malpractice action against the defendant hospital. The plaintiff alleged that the defendant negligently caused her decedent to lose his chance of survival.
The decedent died from a massive intraperitoneal hemorrhage while under the care of the hospital's emergency department. Id., 258-59.
The court granted the defendant's motion for a directed verdict after concluding that the plaintiff failed to prove that the defendant's acts or omissions either led or contributed to the decedent's death. Id., 258.
On appeal, the plaintiff claimed, inter alia, that the court improperly granted the motion for a directed verdict in the defendant's favor because she had produced sufficient evidence to prove that the acts or omissions complained of in the treatment of the decedent, namely, the defendant's failure to perform surgery on the decedent, caused a lost chance for survival.
The Court affirmed the trial court's decision, concluding that the plaintiff had, in fact, failed to demonstrate the causal link necessary to prove her case.
In Wallace v. St. Francis Hospital & Medical Center, the rapid death of the plaintiff's decedent in the defendant's emergency room was held not to be causally related to the failure of the hospital to perform surgery where the decedent died from a massive recent intraperitoneal hemorrhage, which bleeding was unexplained.
On the basis of the defendant's objection as to competence, the court precluded an expert witness from testifying as to proximate cause because he was not a surgeon and, therefore, was not qualified to render an opinion as to a surgical outcome had surgery been performed. Wallace v. St. Francis Hospital & Medical Center, supra, 44 Conn. App. 260.
The Court determined that the trial court had properly precluded the testimony.