Herbert Room v. Caribe Hilton Hotel

Citations: 659 F.2d 5; 1981 U.S. App. LEXIS 17744Docket: 80-1607

Court: Court of Appeals for the First Circuit; September 14, 1981; Federal Appellate Court

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Herbert Room initiated a diversity lawsuit against Caribe Hilton Hotel, seeking damages for a heart attack he experienced on November 24, 1976, while staying at the hotel. After Room's case-in-chief, the district court granted a directed verdict in favor of the hotel, which Room subsequently appealed. 

The key facts, viewed favorably for Room, indicate that after arriving at the hotel, he gambled and, feeling unwell, returned to his room. He called the hotel operator at 7:30 p.m. requesting a doctor without detailing his symptoms. At 11:30 p.m., after no doctor had been contacted, he called again but still did not describe his condition. The operator attempted to reach three listed doctors but could not get through and did not utilize the 24-hour emergency contact for San Jorge Hospital. Eventually, Room sought assistance from friends, who advised him to take a cab to Presbyterian Hospital, where he was diagnosed with a myocardial infarction around 1:15 a.m.

Room was hospitalized for nearly a month, during which he suffered additional cardiac incidents. Following his release, he returned to New York but was unable to continue working due to cognitive issues he developed post-incident. Room claimed that the hotel failed to provide adequate medical care under Puerto Rico law, alleging that this failure caused permanent brain damage and seeking $1 million in damages. The district court, in directing a verdict for the hotel, concluded that the delay in medical attention was not the proximate cause of Room's injuries.

The plaintiff must prove a causal link between the defendant's alleged negligence in providing medical care and the plaintiff's injury, even if a breach of duty is assumed. The focus is first on the plaintiff's permanent brain damage, which was evaluated by Dr. Jose Luis Freyre, a neurologist who examined the plaintiff only after the incidents in question. Dr. Freyre testified that the heart attack on November 24 could have resulted in some loss of cerebral function, but he acknowledged that incomplete hospital records prevented him from definitively linking the heart attack to any brain damage. He could not determine which of three heart-related incidents caused the brain damage, indicating that it was impossible to ascertain causation between the delay in medical assistance and the injury without resorting to speculation. Consequently, a directed verdict for the defendant regarding the brain damage was deemed appropriate. 

Regarding the claim of mental anguish, the plaintiff's testimony indicated he experienced pain and weakness while waiting for medical help, but there was no evidence establishing that the delay was the direct cause of his suffering. The heart attack itself would inherently cause pain, independent of the timeliness of medical assistance. Without evidence to differentiate the impact of the delay from the heart attack, no reasonable jury could conclude that the delay alone resulted in pain or mental anguish. Thus, the directed verdict for the defendant on this claim was also justified.

Proof of mental anguish related to the plaintiff's fear of dying was deemed insufficient. There was a lack of evidence indicating that the plaintiff would not have feared for his life after receiving medical attention, particularly as he experienced two more cardiac crises during his hospitalization, suggesting ongoing danger. The plaintiff failed to specify the duration and intensity of his fear, making it difficult for a jury to assign a monetary value to this emotional injury without resorting to speculation. While there was minimal evidence of mental anguish caused by a delay, it did not meet the threshold to counter a motion for a directed verdict, as supported by the case Trinidad v. Pan American World Airways, Inc. The court affirmed the decision and noted that it was unnecessary to examine additional grounds for the district court's ruling. It did not resolve whether a duty existed or was breached. Under Puerto Rico law, damages for mental suffering can be claimed without proving physical injury. The defendant is not liable for any injury stemming solely from the heart attack itself.