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Juanita W. Keylon v. Robert A. Hill

Citation: Not availableDocket: E2003-01054-COA-R3-CV

Court: Court of Appeals of Tennessee; October 16, 2003; Tennessee; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In the case, the plaintiff, Mrs. Keylon, sued Dr. Hill for medical malpractice following a misdiagnosis and improper treatment of a stroke at a medical facility, leading to severe health consequences. Mrs. Keylon's motion for partial summary judgment was denied, and a trial ensued where Dr. Hill's motion for a directed verdict was granted. The court decided that the evidence indicated that the critical window for administering a stroke treatment drug had passed, absolving Dr. Hill of negligence. The plaintiff appealed, questioning the denial of her summary judgment motion and the appropriateness of the directed verdict. The appellate court affirmed the denial of the summary judgment but reversed the directed verdict, remanding the case for a new trial, citing that the question of negligence should have been left to the jury. The court emphasized the plaintiff's burden to prove negligence and causation, alongside the admissibility of expert testimony in establishing the standard of care. Dr. Scariano's expert testimony was pivotal, asserting that Dr. Hill deviated from the expected standard of care, ultimately influencing the appellate decision to remand for further proceedings.

Legal Issues Addressed

Admissibility of Expert Testimony

Application: Dr. Scariano's qualifications as an expert witness were questioned, but his testimony was considered relevant to determining whether Dr. Hill met the standard of care for stroke treatment.

Reasoning: Expert testimony is only admissible if the witness is licensed and practiced in the relevant field within the year prior to the alleged incident.

Burden of Proof in Medical Negligence

Application: The plaintiff bears the burden of proving that the defendant breached the standard of care, which caused the plaintiff's injuries.

Reasoning: Under Tennessee law, the plaintiff bears the burden of proving the standard of care, that the defendant acted negligently, and that this negligence caused the plaintiff's injuries.

Directed Verdict Standards

Application: The trial court granted a directed verdict in favor of Dr. Hill, concluding that the evidence allowed for only one reasonable conclusion regarding the timing and treatment of Mrs. Keylon's stroke.

Reasoning: The motion for a directed verdict was granted based on the conclusion that symptoms of the stroke began after the patient was last confirmed to be well at 11:00 p.m., with the critical window for drug administration closing at 2:00 a.m.

Medical Malpractice and Standard of Care

Application: The court evaluated whether Dr. Hill adhered to the standard of care in his treatment of Mrs. Keylon, particularly in diagnosing her condition and determining eligibility for stroke treatment.

Reasoning: Dr. Hill denied all allegations of negligence, arguing that any issues were due to independent causes and that he adhered to the standard of care expected of physicians in similar circumstances.

Reviewability of Summary Judgment Denials

Application: The appellate court considered whether the denial of Mrs. Keylon's motion for partial summary judgment was reviewable following the directed verdict in favor of Dr. Hill.

Reasoning: The plaintiff contends that the denial of her summary judgment motion should be reviewable despite the subsequent trial judgment against her, arguing that the relevant legal rule applies only to cases leading to jury verdicts, not directed judgments.