Bingaman v. Grays Harbor Community Hospital

Citations: 699 P.2d 1230; 103 Wash. 2d 831Docket: 50740-6

Court: Washington Supreme Court; May 23, 1985; Washington; State Supreme Court

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In the case of Bingaman v. Grays Harbor Community Hospital, the Supreme Court of Washington examined a wrongful death and survival action stemming from allegations of medical malpractice against Grays Harbor Community Hospital and Dr. Samuel F. Nebel. The jury awarded $1,002,089.03, but the Court of Appeals affirmed only part of this amount, reversing the $412,000 awarded for the decedent's pain and suffering. The Appeals Court mandated a new trial on this issue unless the plaintiff accepted a $206,000 reduction. The case involved Deborah M. Bingaman, who died at 26, shortly after childbirth due to eclampsia—a severe complication of pregnancy. Evidence indicated that her condition worsened due to the defendants' failure to provide appropriate treatment. Prior to her death, Mrs. Bingaman experienced significant physical suffering and demonstrated awareness of her deteriorating state, as noted by medical staff and a fellow patient. She exhibited distress and pleaded for help, ultimately suffering multiple seizures before her death.

Prior to her seizures, Mrs. Bingaman exhibited significant apprehension. A catheterization following her second seizure indicated hemorrhaging due to red blood cells in her urine, suggesting damage to her bladder or kidney. After each seizure, she remained conscious and aware, but experienced severe pain, nausea, vomiting, and headaches, which pointed to cerebral edema and potential liver complications from severe eclampsia. During her transfer to the University Hospital, she was sedated yet restless, moaning and in distress. Upon arrival, she was found bruised and oozing from IV puncture sites, responsive to pain but in a stuporous condition, requiring restraint during medical procedures. Mrs. Bingaman was pronounced dead at midnight.

The court addressed a single issue regarding the Court of Appeals' decision to reduce the jury's damages award for pain and suffering by $206,000, or 50%. The court concluded that the Court of Appeals erred in this reduction, reinstating the trial court's judgment. It emphasized that determining damages is primarily the jury's responsibility, and courts should be hesitant to interfere unless the verdict is influenced by passion or prejudice. The trial court, having observed the trial firsthand, is afforded discretion in these matters, while appellate courts rely solely on the written record. The appellate court found no basis for disturbing the jury's award, affirming that it was not excessive or the result of bias. The trial judge had previously declined to reduce the award or grant a new trial, and the appellate court agreed that the jury's award was within the realm of substantial evidence, dismissing claims of an unrealistic appraisal of damages. Reducing a jury's verdict based on passion or prejudice requires clear and unmistakable evidence, which was not present in this case.

The jury's verdict in this case was not influenced by passion or prejudice, and the court found no reason to intervene based on the size of the damages award alone. The primary question was whether the damages for pain and suffering were so excessive as to shock the court's conscience. The jury's award was deemed appropriate given the substantial evidence of the decedent's pain, fear, and despair during her final days, including her awareness of her impending death. The court affirmed the jury's right to consider both mental and physical suffering, and concluded that the damages awarded did not violate principles of justice or sound judgment. Consequently, the Court of Appeals' reduction of the damages was reversed, and the trial court's judgment was reinstated, with full agreement from the justices.