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Greene v. Elgeziry

Citations: 102 N.E.3d 1030; 92 Mass. App. Ct. 1126Docket: 17–P–780

Court: Massachusetts Appeals Court; February 6, 2018; Massachusetts; State Appellate Court

Narrative Opinion Summary

The case involves a medical malpractice lawsuit filed by the mother of a deceased patient against Dr. Mohamed Elgeziry, alleging negligence in failing to diagnose and treat the patient's heart disease. From April 2011 to November 2012, the patient presented symptoms typical of coronary artery disease to Dr. Elgeziry, who instead diagnosed other conditions and prescribed various treatments, ultimately leading to the patient's death from a heart attack. The initial dismissal of the case by a medical malpractice tribunal was overturned by the appellate court, which found sufficient evidence to suggest a breach of the standard of care and a probable link between Dr. Elgeziry's conduct and the patient's death. The tribunal's role was to assess the evidence in favor of the plaintiff without weighing its credibility. Expert testimony criticized Dr. Elgeziry's treatment decisions, and the court concluded that the plaintiff had raised a legitimate question of liability. The case was remanded for further proceedings, with implications for vicarious liability claims involving Harbor Medical Associates, P.C., associated with Dr. Elgeziry.

Legal Issues Addressed

Causation in Medical Malpractice

Application: Despite challenges to causation, the court found sufficient evidence suggesting a probable link between Dr. Elgeziry's alleged negligence and Abraham's death, which was supported by expert testimony.

Reasoning: Although Dr. Elgeziry contends that causation between his alleged negligence and Abraham's death is inadequately established, the requirements for overcoming a directed verdict on causation are minimal. Evidence suggesting a probable link between the harm and Dr. Elgeziry's conduct was found in the expert's opinion regarding the necessary steps to manage Abraham's heart condition.

Medical Malpractice Standard of Care

Application: The court reviewed whether Dr. Elgeziry's treatment of Abraham met the accepted medical standard of care for a patient presenting symptoms typical of coronary artery disease.

Reasoning: Dr. Genecin criticized Dr. Elgeziry for prescribing testosterone cream to Abraham without evidence of hormone deficiencies, noting that this could exacerbate cardiac issues. He concluded that Dr. Elgeziry's care deviated from the accepted standard, failing to recognize Abraham's symptoms as signs of coronary artery disease, not referring him for necessary cardiac evaluations, and delaying the diagnosis and treatment of his condition.

Negligence and Vicarious Liability

Application: The claims against Dr. Elgeziry included negligence and vicarious liability, with implications for Harbor Medical Associates, P.C., based on his alleged conduct.

Reasoning: The claims revolve around negligence and vicarious liability, with General Laws c. 231, § 60B, applying to all treatment-related claims against healthcare providers.

Role of Medical Malpractice Tribunal

Application: The tribunal's decision was reversed because it failed to properly assess the sufficiency of evidence favorably toward the plaintiff, without weighing the credibility of the evidence.

Reasoning: The appellate court reversed this decision, stating that a plaintiff's offer of proof must demonstrate the health care provider's failure to conform to good medical practice and establish resulting damages. The tribunal's role is to assess the sufficiency of the evidence favorably toward the plaintiff, without weighing the evidence's credibility.