Hill v. Rhinehart
2015 WL 6023197, 45 N.E.3d 427, 2015 Ind. App. LEXIS 681 (2015)
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Rule of Law:
A physician is not liable for medical malpractice for an error in diagnosis or treatment if the physician exercised the degree of skill and learning ordinarily possessed and used by physicians under the same or similar circumstances. A jury instruction reflecting this principle is a correct statement of the law.
Facts:
- On December 6, 1999, John A. Hill was admitted to Parkview Memorial Hospital for a cardiac catheterization performed by Dr. Ryan, which revealed severe coronary artery disease.
- The following day, Dr. Lloyd performed coronary artery bypass surgery on Hill, during which Hill received Heparin, an anticoagulant.
- Post-surgery, Hill developed complications, including a significant drop in platelet count, leading Dr. Ryan to suspect a rare reaction called Heparin-Induced Thrombocytopenia (HIT) and order subcutaneous Heparin stopped on December 9.
- Unbeknownst to the physicians, Hill continued to receive small doses of Heparin through IV line flushes as per hospital protocol.
- Hill's condition deteriorated, and on December 16, Dr. Rhinehart, suspecting a different condition (DIC), ordered a large dose of Heparin to be administered intravenously.
- On December 17, Dr. Rhinehart reversed course, discontinued all Heparin, ordered a test for HIT, and began administering a non-Heparin anticoagulant. Hill's platelet count then began to rebound.
- Due to extensive necrosis and gangrene that had developed in his limbs, Hill underwent amputations of his left arm below the elbow and both legs above the knee between December 20 and December 28, 1999.
Procedural Posture:
- John Hill entered into a settlement agreement with Parkview Memorial Hospital for $250,000.
- Hill filed a proposed complaint for medical malpractice against Drs. Ryan, Lloyd, Csicsko, and Rhinehart with the Indiana Department of Insurance.
- The medical review panel found that the doctors had complied with the appropriate standard of care.
- Hill then entered into a settlement agreement with the Indiana Patient's Compensation Fund for one million dollars.
- Hill filed a medical malpractice lawsuit against the four physicians in an Indiana trial court.
- At the conclusion of Hill's case-in-chief at trial, the court granted a judgment on the evidence for Drs. Lloyd and Csicsko, dismissing them from the case.
- The jury returned a verdict in favor of the remaining defendants, Drs. Ryan and Rhinehart.
- Hill, as appellant, appealed the judgment on the evidence and the jury verdict to the Court of Appeals of Indiana.
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Issue:
Is a jury instruction that states a physician is not negligent for an error in diagnosis or treatment, provided the physician exercised reasonable care and ordinary skill, a correct statement of Indiana law?
Opinions:
Majority - Riley, J.
Yes, the jury instruction is a correct statement of the law. The law does not hold physicians to a standard of guaranteeing a cure or a good result. A physician is not negligent for mistaking a diagnosis or making an error during treatment, so long as they exercise the reasonable care and ordinary skill expected of a physician under similar circumstances. Citing longstanding Indiana precedent like Fall v. White and Dahlberg v. Ogle, the court affirmed that the instruction properly guided the jury to focus on the standard of care, rather than on the poor outcome alone. The instruction correctly informed the jury that medicine is not an exact science and that a mistaken diagnosis does not constitute negligence if the physician used reasonable skill and care in the process.
Analysis:
This decision reaffirms the 'error of judgment' doctrine in Indiana medical malpractice law, which distinguishes between a negligent breach of the standard of care and a non-negligent mistake made while exercising reasonable professional judgment. It solidifies that the focus of a malpractice inquiry is on the physician's conduct and adherence to professional standards, not merely on the negative outcome for the patient. By upholding this type of jury instruction, the court provides a framework that protects healthcare providers from liability for unfortunate outcomes that occur despite competent care, thereby reinforcing a high bar for plaintiffs to prove a breach of the standard of care.
