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Teresa Lynn Stanfield v. John Neblett, Jr., M.D.

Citations: 339 S.W.3d 22; 2010 Tenn. App. LEXIS 373Docket: W2009-01891-COA-R3-CV

Court: Court of Appeals of Tennessee; July 23, 2010; Tennessee; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

The case involved a medical malpractice claim by Teresa Stanfield against Dr. John Neblett, Jr., concerning the treatment of her daughter, Trista Jane Greene, following an ATV accident. The jury found that Dr. Neblett deviated from the standard of care but that this deviation was not the legal cause of Greene's death. Stanfield appealed, arguing errors in the trial court's judgment, including issues with directed verdicts, expert testimonies, and the use of visual aids during trial. The Tennessee Court of Appeals affirmed the trial court's rulings, holding that there was no abuse of discretion in the admission of evidence or expert testimony. The court found that the jury instructions and verdict form were appropriate and that the expert witnesses met the locality rule requirements. The appellate court upheld the denial of Stanfield's motion for a new trial, concluding that the trial was conducted fairly and without legal error. The costs of the appeal were assigned to Ms. Stanfield and her surety, finalizing the judgment in favor of Dr. Neblett.

Legal Issues Addressed

Abuse of Discretion in Admissibility of Evidence

Application: The trial court’s decisions on evidentiary matters were upheld, as Ms. Stanfield failed to show any abuse of discretion that resulted in prejudice.

Reasoning: The admissibility of expert testimony is assessed under an abuse of discretion standard, as established in Wilson v. Patterson.

Directed Verdict and Standard of Review

Application: Ms. Stanfield's motion for a directed verdict was denied on the basis that reasonable minds could differ regarding the evidence, which included testimony about the nursing staff's failure to notify Dr. Neblett.

Reasoning: The appeal applies the same legal standards as the trial court, focusing on whether reasonable minds could reach differing conclusions based on the evidence presented.

Expert Testimony and Rule 26 Disclosures

Application: The trial court allowed Dr. Neblett's experts to testify within the scope of their Rule 26 disclosures, emphasizing that discovery rules aim to prevent 'trial by ambush.'

Reasoning: The court mandated that the experts testify in alignment with these disclosures, allowing them to respond to criticisms from Ms. Stanfield’s experts but prohibiting them from presenting new opinions.

Impeachment of Expert Witnesses

Application: The court allowed the impeachment of Ms. Stanfield's experts using medical treatises, finding no error in the questioning based on the ATLS Guidelines.

Reasoning: Tennessee Rule of Evidence 618 permits the use of published treatises for impeaching an expert's credibility, provided the treatise is established as a reliable authority.

Locality Rule for Expert Qualification

Application: The court determined that Dr. Neblett’s experts were familiar with the local standard of care, meeting the requirements of Tennessee Code Annotated §29-26-115(b).

Reasoning: According to Tennessee Code Annotated §29-26-115(b), an expert witness in a medical malpractice case must be licensed in Tennessee or a contiguous state and have practiced in that area in the year prior to the incident.

Medical Malpractice and Standard of Care

Application: The case addressed whether Dr. Neblett deviated from the accepted standard of care in treating Trista Jane Greene. The jury concluded that although there was a deviation, it was not the legal cause of Greene's death.

Reasoning: The jury found that Dr. Neblett deviated from the accepted standard of care but concluded that this deviation was not the legal cause of Greene's death.

Use of Visual Aids in Jury Arguments

Application: The court permitted the use of PowerPoint presentations and transcript excerpts during opening and closing arguments, consistent with Tennessee Code Annotated § 20-9-303.

Reasoning: Tennessee Code Annotated § 20-9-303 allows the use of visual aids in jury arguments, and Dr. Neblett’s counsel acted within this provision.