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Titus v. Department of Corrections

HEALTH LAW

Hannah Rogers

In Titus v. Department of Corrections, 496 P.3d 412, the supreme court held that “the matter at issue” in determining “whether an expert’s training, expertise, or certification is directly related to the matter at issue” in a medical malpractice action, refers to the underlying circumstances of the medical event or treatment giving rise to the action. (Id. at 412). Joel Titus died shortly after being treated for alcohol withdrawal syndrome in the emergency room at Fairbanks Memorial Hospital. (Id. at 414). Titus’s estate sued, among other parties, Golden Heart Emergency Physicians, PC “Golden Heart,” the company providing emergency room services at the hospital at the time of Titus’ treatment, for medical malpractice. (Id.). Golden Heart moved for summary judgment, relying on an affidavit from a board-certified emergency doctor stating that the doctors had not breached the relevant standard of care. (Id.). The estate opposed summary judgment with Dr. Lisa Lindquist’s affidavit stating that the Golden Heart doctors did in fact breach the standard of care. (Id.). Dr. Lindquist is not an emergency room doctor or certified in emergency medicine. (Id. at 415). Instead, Dr. Lindquist had learned about alcohol withdrawal in medical school and had participated in emergency medical clinical rotations. (Id.). The superior court granted Golden Heart’s summary judgment, finding that Dr. Lindquist was not qualified on the relevant standard of care for an emergency room physician. (Id.). The estate sought a motion in limine prohibiting the Department of Corrections, another defendant, from introducing any evidence blaming Golden Heart for Titus’s death, which the court denied. (Id.). The estate appealed, and the supreme court granted petition for appeal. (Id.). The supreme court found that while Dr. Lindquist was not certified in emergency care, the superior court had not addressed whether Dr. Lindquist’s certification was “directly related to the . . . matter at issue.” (Id. at 417). As a matter of first impression, the supreme court held that “matter at issue” in the medical malpractice context refers to the underlying circumstances of the medical event or treatment giving rise to the medical malpractice action. (Id. at 418). Therefore, whether an expert’s training, expertise, or certification is directly related varies depending on the facts and circumstances. (Id.). The supreme court then held it was error to not qualify Dr. Lindquist as an expert simply because she is not board certified in emergency medicine. (Id.). Therefore, it was error to grant summary judgment to Golden Heart because there is a dispute of fact as to whether the treating physicians adhered to the standard of care. (Id.). The “matter of issue” in medical malpractice suits refers to the underlying circumstances of the medical event at issue. (Id. at 412).

Titus v. Department of Corrections

HEALTH LAW

Hannah Rogers

In Titus v. Department of Corrections, 496 P.3d 412, the supreme court held that “the matter at issue” in determining “whether an expert’s training, expertise, or certification is directly related to the matter at issue” in a medical malpractice action, refers to the underlying circumstances of the medical event or treatment giving rise to the action. (Id. at 412). Joel Titus died shortly after being treated for alcohol withdrawal syndrome in the emergency room at Fairbanks Memorial Hospital. (Id. at 414). Titus’s estate sued, among other parties, Golden Heart Emergency Physicians, PC “Golden Heart,” the company providing emergency room services at the hospital at the time of Titus’ treatment, for medical malpractice. (Id.). Golden Heart moved for summary judgment, relying on an affidavit from a board-certified emergency doctor stating that the doctors had not breached the relevant standard of care. (Id.). The estate opposed summary judgment with Dr. Lisa Lindquist’s affidavit stating that the Golden Heart doctors did in fact breach the standard of care. (Id.). Dr. Lindquist is not an emergency room doctor or certified in emergency medicine. (Id. at 415). Instead, Dr. Lindquist had learned about alcohol withdrawal in medical school and had participated in emergency medical clinical rotations. (Id.). The superior court granted Golden Heart’s summary judgment, finding that Dr. Lindquist was not qualified on the relevant standard of care for an emergency room physician. (Id.). The estate sought a motion in limine prohibiting the Department of Corrections, another defendant, from introducing any evidence blaming Golden Heart for Titus’s death, which the court denied. (Id.). The estate appealed, and the supreme court granted petition for appeal. (Id.). The supreme court found that while Dr. Lindquist was not certified in emergency care, the superior court had not addressed whether Dr. Lindquist’s certification was “directly related to the . . . matter at issue.” (Id. at 417). As a matter of first impression, the supreme court held that “matter at issue” in the medical malpractice context refers to the underlying circumstances of the medical event or treatment giving rise to the medical malpractice action. (Id. at 418). Therefore, whether an expert’s training, expertise, or certification is directly related varies depending on the facts and circumstances. (Id.). The supreme court then held it was error to not qualify Dr. Lindquist as an expert simply because she is not board certified in emergency medicine. (Id.). Therefore, it was error to grant summary judgment to Golden Heart because there is a dispute of fact as to whether the treating physicians adhered to the standard of care. (Id.). The “matter of issue” in medical malpractice suits refers to the underlying circumstances of the medical event at issue. (Id. at 412).