Baptist Health Medical Group, Inc. v. Wellman

The Indiana Court of Appeals recently reversed the trial court’s order for summary judgment in Baptist Health Medical Group, Inc. v. Wellman. Summary judgment allows a court to make a ruling on evidence without going to trial. When a party moves for summary judgment, they must show there is no genuine issue of material fact. In other words, the moving party must show that all the evidence can only support a conclusion in their favor. Then, the non-moving party has the burden of showing there is an issue of material fact by presenting evidence. The court then considers all the evidence presented, while resolving all ambiguities in the non-moving party’s favor. Finally, the court makes a ruling on the motion.

This case arises from a medical malpractice suit brought by Carla Wellman, widow of David Wellman. In 2017, David was admitted to Baptist Health’s emergency room for respiratory failure. Because David previously had mitral valve replacement and was at risk of developing endocarditis, cardiologist Dr. Srinivas Manchikalapudi (Dr. Manchi) assessed David’s cardiac issues. Dr. Manchi performed a transesophageal echocardiogram (TEE), an ultrasound that examines the heart. The goal of the procedure was to determine if David had endocarditis, which is life-threatening inflammation in the heart Dr. Manchi found no evidence of myocarditis, and David’s condition began to improve. Unfortunately, before he was discharged, David suffered a brain bleed and was transported to University of Louisville Hospital. There, the doctors performed another TEE which showed several lesions on David’s mitral valve. David passed away in Louisville.

In 2019, Carla filed a complaint against Baptist Health and Dr. Manchi for medical malpractice resulting in David’s death. A medical review panel made up of an ER doctor, an infectious disease physician, and a cardiologist evaluated David’s case. The cardiologist, Dr. Jarrod Frizzell, was the only one of the three to conclude Baptist Health and Dr. Manchi failed to meet the standard of care while treating David.

Then in 2022, Wellman filed a partial motion for summary judgment regarding the standard of care. Baptist Health responded to this motion with three pieces of evidence: an affidavit from Dr. Manchi, the testimony of Dr. Frizzell, and medical records from University of Louisville Hospital. The trial court granted Wellman’s partial motion for summary judgment, concluding there was not genuine issue of material fact relating to Dr. Manchi’s use of the TEE. Essentially, the trial court decided that no jury could conclude Dr. Manchi’s interpretation of the TEE met the standard of care. The trial court reasoned that Baptist Health needed to present more evidence than just Dr. Manchi’s affidavit. Specifically, Baptist Health needed outside, expert testimony to support their case.

Baptist Health appealed this decision to the Indiana Court of Appeals. The court had to decide if the three pieces of evidence Baptist Health presented were sufficient expert testimony that created a genuine issue of material fact. To support her motion for summary judgment, Wellman pointed to Dr. Frizzell’s testimony that Dr. Manchi failed to read the TEE correctly which increased the likelihood of David’s death. In response, Baptist Health highlighted Dr. Manchi’s affidavit where he explained how he met the standard of care while doing the TEE. Additionally, Baptist Health showed David’s medical records from University of Louisville hospital which supported Dr. Manchi’s conclusions. Finally, Baptist Health pointed to Dr. Frizzell’s testimony where he admitted the standard of care can vary based on many different factors, such as the individual patient, anatomy, and the doctor’s judgment.

Taking everything into consideration, the Indiana Court of Appeals reversed the trial court’s entry of summary judgment. The court concluded the three pieces of evidence presented by Baptist Health created a genuine issue of material fact. To support this decision, the court looked to two Indiana Supreme Court cases. In Chi Yun Ho v. Frye (2008), the supreme court decided that because expert opinion is so vital in medical malpractice cases, it “takes on the character of evidentiary fact.” However, they specified that mere speculation would not create a genuine issue. For example, an affidavit that only includes denials and conclusions without specific facts about patient’s care will not survive summary judgment. After all, the parties must be sure to address the legal standard, which in medical malpractice cases is whether the patient’s treatment met the standard of care.

The court of appeals also emphasized that the focus in summary judgment is whether “a conflict of evidence may exist” not necessarily whether the evidence would lead to a certain verdict. (Siner v. Kindred Hosp. Ltd. P’ship (2016)). In David’s case, the court was met with a clear conflict of evidence. On one side, Dr. Frizell’s medical review opinion and affidavit argued Dr. Manchi failed to meet the standard of care. On the other side, Dr. Manchi’s affidavit included explicit facts detailing his credentials, his knowledge of the standard of care, and the course of treatment. Additionally, University of Louisville Hospital records showed no diagnosis of endocarditis, even after a follow-up TEE was done. The “smoking-gun” came from Dr. Frizzell’s own deposition, in which he conceded that the standard of care can change depending on a multitude of factors. When considered as a whole, the evidence presented by Baptist Health created a genuine issue of material fact which precluded summary judgment in favor of Wellman.

So, what does this mean for future medical malpractice cases in Indiana? While this case isn’t making landmark change in Indiana law, it does follow a line of case changing the burdens of summary judgment. This case technically lowers the burden the non-moving party needs to meet to survive a motion for summary judgment. The court will still focus heavily on evidence, rather than speculation during summary judgment, but this decision emphasizes that even cases where a conflict of evidence might exist can withstand summary judgment. Because expert testimony is so important in medical malpractice cases and expert opinions can often vary wildly, this burden shift will likely increase the number of cases that survive summary judgment. In the end, the Court of Appeals decision in Baptist Health Medical Group, Inc. v. Wellman might increase the number of medical malpractice cases that make it to trial.

Indiana Medical Malpractice Act Explained

Medical malpractice cases revolve around the duty of healthcare professionals to provide a standard of care that meets or exceeds the expectations of their peers. When these standards are not met, patients may suffer harm, and it becomes crucial to hold healthcare professionals accountable for their actions.

In Indiana, the Medical Malpractice Act plays a vital role in addressing claims of medical mistakes and ensuring adequate compensation for patients injured by such errors.

The Indiana Medical Malpractice Act stands as legislation designed to reform medical malpractice by establishing a structured process for pursuing claims of alleged medical negligence. Under this act, a complaint must be filed for each instance of alleged malpractice, which is then reviewed by a panel of medical practitioners specializing in the same or a similar area of practice. This panel, composed of three healthcare professionals and one attorney acting as the chairperson, evaluates the evidence presented and determines whether the defendant failed to meet the appropriate standard of care, whether the defendant’s actions contributed to harm, and the extent of the patient’s disability or permanent impairment resulting from the incident.

The combination of the Indiana Medical Malpractice Act and the Baptist Health Medical Group, Inc. v. Wellman case illustrates the intricate framework of medical malpractice litigation in Indiana. The Act establishes a structured process for evaluating medical negligence claims, while the case review demonstrates the impact of this legislative framework on the burden of proof during summary judgment. As medical malpractice cases continue to arise, the role of expert testimony and the careful examination of conflicting evidence remain paramount in determining the viability of claims. By understanding the nuances of the Indiana Medical Malpractice Act and its implications, individuals can better navigate the legal landscape when pursuing medical malpractice cases in the state.

If you or a loved one have been impacted as the result of medical malpractice, contact an experienced attorney at Hurst Limontes and we will be happy to navigate through the complexities of your case and discuss your options with you. We work on a contingency basis, meaning there is no cost to you unless we reach a settlement or jury verdict award on your behalf.

Call 317-636-0808 or email us for a FREE and confidential consultation.