Justia Washington Supreme Court Opinion Summaries

In this class action lawsuit, the trial court found that the State wrongfully denied health benefits to a number of its part-time employees. The issue this case presented for the Supreme Court's review was how to value the damages suffered by that group of employees when they were denied health benefits. The State argued that the only damages to the employees were immediate medical expenses paid by employees during the time they were denied health benefits. But evidence showed that people denied health care benefits suffer additional damage. They often avoid going to the doctor for preventive care, and they defer care for medical problems. This results in increased long-term medical costs and a lower quality of life. Based on this evidence, the trial court correctly rejected the State's limited definition of damages because it would significantly understate the damages suffered by the employees. The Supreme Court affirmed. View "Moore v. Health Care Auth." on Justia Law

Christiana Anaya suffered from uncontrolled diabetes, which left her susceptible to serious infections. She went to the Toppenish Community Hospital with a urinary tract infection. Blood test results revealed Ms. Anaya had a yeast infection. The lab called Ms. Anaya's primary care facility (the Yakima Valley Farm Workers Clinic) where Respondent Dr. Mark Sauerwein was covering for Ms. Anaya's usual provider. Sauerwein was concerned about the lab results. Due to the serious nature of a blood infection, the doctor decided that if Ms. Anaya was feeling ill, she should come in immediately for treatment. If she was feeling better, it was more likely that the test result was a false positive, a common occurrence in microbiology labs. Dr. Sauerwein used the complete clinical picture available to him to conclude that the lab result was a false positive resulting from contamination but had the nurse contact Mrs. Anaya to move her next appointment up to the following week. Dr. Sauerwein did not tell Mrs. Anaya about the test result. The lab positively identified candida glabrata as the yeast in Ms. Anaya's blood. An infection of glabrata in the blood is serious. Lab microbiologists entered this information into Ms. Anaya's medical record but did not notify Dr. Sauerwein, the Clinic, or anyone else about the positive test result. Before Ms. Anaya's next visit to the Clinic, her condition worsened. Ms. Anaya went to Yakima Memorial Hospital where she was prescribed amphotericin B, which is highly toxic to the kidneys. Given the compromised state of Ms. Anaya's kidneys from her diabetes, a health care provider would not normally prescribe amphotericin B until positively identifying glabrata. Unfortunately, the amphotericin B treatment came too late to stop the infection from spreading to the internal organs. Ms. Anaya died at age 32 of cardiac arrest, deprivation of oxygen to the brain, and fungal sepsis; all stemming from type II diabetes mellitus. Mr. Anaya Gomez, as personal representative of Ms. Anaya's estate, filed suit against Dr. Sauerwein and the Clinic for malpractice. Three weeks before the jury trial, the estate moved to add a claim for failure to obtain informed consent. At the close of Mr. Anaya's case, the defense moved for judgment as a matter of law on the informed consent claim. The trial judge granted the motion and dismissed the informed consent claim, arguing that case law precluded the claim in misdiagnosis cases. The jury then found Dr. Sauerwein did not breach any duty owed to Ms. Anaya. After its review, the Supreme Court concluded that when a health care provider rules out a particular diagnosis based on the patient's clinical condition-including test results, medical history, presentation upon physical examination, and any other circumstances surrounding the patient's condition that are available to the provider the provider may not be liable for informed consent claims arising from the ruled out diagnosis. The Court affirmed the appellate court, which affirmed the trial court's judgment. View "Gomez v. Sauerwein" on Justia Law

Rival hospice operators challenged the State Department of Health's decision to grant a certificate of need to Odyssey Healthcare Operating B, LP and Odyssey Healthcare Inc. in connection with the settlement of a federal lawsuit. The superior court revoked the certificate; the Court of Appeals reinstated the certificate. The Supreme Court affirmed the Court of Appeals. View "King County Pub. Hosp. #2 v. Dep't of Health" on Justia Law

Respondent Robert Chaney was fired from his position and argued his termination violated the federal Family and Medical Leave Act of 1993 (FMLA). The employer, Providence Health Care d/b/a Sacred Heart Medical Center & Children's Hospital (Providence), claimed no violation of the FMLA occurred. The trial court denied motions for a directed verdict on the issue by both Chaney and Providence. Based upon undisputed facts, the Supreme Court held that the trial court erred in failing to grant Chaney's motion for a directed verdict that as a matter of law the hospital violated the FMLA. In 2005, his wife fell ill after giving birth, Chaney himself suffered a back injury, and he relied heavily on FMLA leave over the next two years. By June 2007, Chaney had used up most of his FMLA leave and had been donated leave from other employees. The record indicated that Providence administration and other staff were growing resentful that Chaney had taken so much time off. In 2007, an employee reported that Chaney appeared fatigued and incoherent. Although no claim was made that his work was compromised, Chaney was ordered to report for drug testing. The drug test was positive for methadone. Chaney had a prescription for methadone to treat back pain, but the doctor who gave the drug test noted that Chaney "[m]ay need fitness for duty evaluation or visit to his Dr. to fine tune his medication." A few months later, Chaney indicated he was prepared to return to work. The record reflected that Chaney was erroneously informed he needed Providence's permission to return to work. This violated the FMLA, under which Chaney could only be required to get authorization from his own health care provider. Chaney went to Providence's doctor, and administration told him the hospital would not allow him to return to work unless their doctor changed his recommended restriction. The hospital's doctor refused to change his recommendation. Subsequently, Chaney was fired. Providence claimed the termination was proper because Chaney failed to provide a valid fitness for work certification as required under the FMLA. View "Chaney v. Providence Health Care" on Justia Law

The issue before the Supreme Court concerned whether, in civil litigation, a party could decline to produce requested discoverable information on the basis that to locate the information would require consulting privileged documents. Petitioners Peacehealth and St. Joseph Hospital sought a protective order to prevent them from being required to review its quality assurance records to identify discoverable medical records in a medical negligence suit. The Court's policy favoring open discovery required "privileges in derogation of the common law" be narrowly construed. Upon review of the matter, the Supreme Court held that the prohibition of "review" in Washington's quality improvement statute, RCW 70.41.200, refers to external review and not internal review. The Court held in this case that the hospital's consultation of its own privileged database to identify relevant, discoverable files that fall outside of the privilege would not violate the hospital's privilege. The Court affirmed the Court of Appeals and reversed the trial court. View "Lowy v. PeaceHealth" on Justia Law