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Hubbard v. Calvin

Citations: 83 Cal. App. 3d 529; 147 Cal. Rptr. 905; 1978 Cal. App. LEXIS 1787Docket: Civ. 16499

Court: California Court of Appeal; August 3, 1978; California; State Appellate Court

Narrative Opinion Summary

In this medical malpractice case, the plaintiff sued the defendant, a physician, for alleged negligence during a cerebral angiogram that resulted in the plaintiff's partial paralysis. The jury awarded the plaintiff $77,000 in damages. On appeal, the defendant challenged a special jury instruction that implied negligence if the defendant's medical technique was not approved by a respectable minority of neurosurgeons. The appellate court found the instruction improper as it conflicted with the established standard of care, which does not rely on minority opinions. The erroneous instruction was deemed a reversible error, as it likely influenced the jury's verdict. Furthermore, the court identified additional instructional errors, including misguidance on causation and reliance on expert testimony. These compounded errors warranted the reversal of the judgment. The appellate court's decision underscored the importance of adhering to established legal standards and avoiding instructional errors that could prejudice the jury's deliberations. Consequently, the judgment was reversed, and a petition for rehearing and a Supreme Court hearing were both denied.

Legal Issues Addressed

Erroneous Jury Instruction

Application: The trial court's special instruction improperly suggested negligence based on the opinions of a minority, which was not aligned with established legal standards, constituting reversible error.

Reasoning: Thus, the court found that the instruction should not have been given, as it improperly suggested negligence based on the opinions of a minority rather than established standards of care.

Improper Jury Instruction on Causation

Application: The court improperly instructed the jury that the arteriogram performed was a substantial factor in causing the plaintiff's injury, removing the issue of legal causation from the jury's consideration.

Reasoning: Additionally, the court improperly instructed the jury, over objection, that the arteriogram performed by the defendant was a substantial factor in causing the plaintiff's injury.

Reversal Due to Prejudicial Error

Application: The erroneous instruction likely influenced the jury's verdict, indicating potential prejudice and warranting a reversal.

Reasoning: The likelihood that the jury's verdict was influenced by this erroneous instruction indicates potential prejudice, warranting a reversal without speculation on the verdict's basis.

Standard of Care in Medical Malpractice

Application: The court emphasized that the standard of care requires physicians to exercise a reasonable degree of skill, knowledge, and care typical of the medical profession, without reference to a 'respectable minority.'

Reasoning: The court highlighted that the standard of care in medical malpractice requires physicians to exercise a reasonable degree of skill, knowledge, and care typical of the medical profession, without reference to a 'respectable minority.'

Use of Expert Testimony in Establishing Standard of Care

Application: The trial court erred in initially suggesting that the jury could not rely solely on expert testimony to determine the standard of care, contradicting established law.

Reasoning: Further errors included the trial court's incorrect initial reading of BAJI No. 6.30, suggesting the jury could not rely solely on expert testimony to determine the standard of care, conflicting with established law.