Moodie v. Santoni
292 Md. 582 (1982)
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Rule of Law:
The issue of contributory negligence must be submitted to a jury if there is any legally sufficient evidence, however slight, from which a rational mind could infer that the plaintiff failed to exercise ordinary care for their own safety. A court may only decide the issue as a matter of law if there is no evidence of acts or conduct from which a reasonable mind could find or infer negligence on the plaintiff's part.
Facts:
- In January 1972, Mario Santoni was hired by the City of Baltimore and, after a physical exam revealed T.B. bacilli, was referred to a city health clinic.
- The clinic prescribed Isoniazid (INH) as a preventative therapy, a drug known to have a potential side effect of causing hepatitis.
- The clinic followed a U.S. Public Health Service protocol that required staff to question patients monthly about symptoms of hepatitis and to stress the importance of reporting them.
- From March to June 1972, Santoni began experiencing symptoms consistent with hepatitis, including fatigue, decreased appetite, abdominal discomfort, and changes in stool and urine color.
- During his monthly clinic visits in May and June 1972, clinic records, based on the established protocol, noted that Santoni reported having "no problem" or "no adverse reaction."
- Santoni’s condition worsened, and he was admitted to a hospital on June 22, 1972, where he was diagnosed with hepatitis.
- Santoni died on July 3, 1972, from a toxic reaction to INH causing hepatitis.
Procedural Posture:
- Mario Santoni's widow and personal representative sued several physicians and others in a Maryland trial court for wrongful death.
- The trial court submitted the case to a jury, which returned a verdict finding that Mario Santoni had been contributorily negligent.
- Santoni's widow (plaintiff-appellant) appealed the judgment to the Court of Special Appeals of Maryland, the state's intermediate appellate court.
- The Court of Special Appeals held that there was insufficient evidence of contributory negligence as a matter of law, reversed the trial court's judgment, and remanded for a new trial solely on the issue of damages.
- The physicians and other defendants (appellees at the intermediate court, now petitioners) successfully petitioned the Court of Appeals of Maryland, the state's highest court, for a writ of certiorari to review the decision of the Court of Special Appeals.
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Issue:
Is the issue of a patient's contributory negligence a question for the jury when evidence, including clinic records and testimony about standard procedures, suggests the patient failed to report symptoms of a drug's known side effects?
Opinions:
Majority - Smith, J.
Yes. The question of a patient's contributory negligence is for the jury when there is evidence from which a reasonable mind could infer the patient failed to report symptoms. In Maryland, even meager evidence of negligence is sufficient to carry the case to the jury. The defense presented evidence of the clinic's strict protocol for questioning patients about symptoms and clinic records indicating Santoni reported no adverse reactions. From this evidence, a jury could rationally infer that Santoni was, in fact, questioned about his symptoms but failed to report them. This failure to report, if believed by the jury, could constitute a failure to exercise ordinary care for his own safety. Therefore, the intermediate appellate court erred in taking this question away from the jury and deciding it as a matter of law.
Analysis:
This decision reaffirms Maryland's very low evidentiary threshold for sending the issue of contributory negligence to a jury. It clarifies that the standard is not whether the inference of negligence is "more likely than not," but whether there is any legally sufficient evidence from which a reasonable mind could infer negligence. By reversing the appellate court, this ruling makes it significantly harder for plaintiffs to obtain a judgment as a matter of law on the issue of their own negligence. This strengthens the position of defendants, who need only present a "scintilla" of evidence—more than mere conjecture but not necessarily a preponderance—to ensure a jury will decide the plaintiff's fault.
