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Huie v. Newcomb Hospital

Citations: 112 N.J. Super. 429; 271 A.2d 607; 1970 N.J. Super. LEXIS 377

Court: New Jersey Superior Court Appellate Division; December 7, 1970; New Jersey; State Appellate Court

Narrative Opinion Summary

In this appellate case, Dr. Miles E. Drake challenges a court order mandating the submission of his unpublished article for examination in a medical negligence lawsuit. The case involves a minor plaintiff who alleges permanent blindness due to negligent oxygen administration at birth, implicating Dr. Drake during his tenure at Newcomb Hospital. The plaintiffs seek damages for the child’s injuries and associated expenses. During discovery, Dr. Drake declared no recognition of authoritative medical treatises on retrolental fibroplasia, despite being familiar with certain texts. He mentioned authoring a paper on the subject, which remained unpublished. The trial court granted the plaintiffs' motion to inspect Dr. Drake's paper, emphasizing the broad scope of discovery rules aimed at revealing pertinent evidence. The decision was rooted in potential insights the paper might provide regarding authoritative literature and its implications on Dr. Drake's credibility. By affirming the lower court's decision, the appellate court underscored the paper's relevance, particularly concerning the medically significant link between oxygen use and retrolental fibroplasia, thus furthering the inquiry into the alleged negligence.

Legal Issues Addressed

Authority in Medical Literature

Application: The defendant's acknowledgment of familiarity with certain texts, but rejection of them as authoritative, highlighted the need to scrutinize his own unpublished work for credibility purposes.

Reasoning: During discovery, Dr. Drake's deposition revealed that he does not recognize any authoritative medical treatises on retrolental fibroplasia. Although he acknowledged familiarity with some texts, he rejected them as authoritative.

Discovery in Medical Negligence Cases

Application: The court applied broad discovery rules to allow the examination of an unpublished article by the defendant to uncover relevant evidence regarding medical negligence.

Reasoning: The court cited precedents supporting the liberal interpretation of discovery rules, asserting that the inspection of Dr. Drake's article could yield information regarding authoritative literature he may have used, potentially affecting his credibility during cross-examination.

Relevance of Unpublished Articles in Litigation

Application: The court deemed the unpublished article pertinent as it discusses the link between oxygen use and retrolental fibroplasia, which is central to the case of alleged negligence.

Reasoning: Additionally, the article discusses the link between oxygen use and retrolental fibroplasia, making it pertinent for further inquiry.