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Ohio Supreme Court examines jury instructions in medical negligence cases

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Sunday, November 24, 2024

Ohio Supreme Court examines jury instructions in medical negligence cases

State Supreme Court
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Justice Michael P. Donnelly | Ohio Supreme Court Website

The Supreme Court of Ohio is set to hear a significant case concerning the jury process in medical negligence lawsuits. The case involves the estate of Scott Boldman, who died following complications from an emergency appendectomy in 2017. The estate filed a lawsuit alleging medical malpractice and wrongful death against nurse anesthetist Sandra Ward, Dr. Vincent Phillips, Consolidated Anesthesiologists, and Good Samaritan Hospital.

During the trial, jurors were tasked with determining if Ward was negligent and if her actions were the proximate cause of Boldman's injuries and subsequent death. Six out of eight jurors found Ward negligent but concluded that her actions did not cause Boldman's injuries or death. Consequently, the verdict favored Ward and other defendants.

Janet Hild, administrator of Boldman's estate, appealed to the Second District Court of Appeals, which ruled that all eight jurors should have participated in deciding both negligence and causation questions. This decision prompted further appeal to the Supreme Court by Good Samaritan Hospital and others involved.

The core issue lies in whether only jurors who find negligence can vote on causation—a stance supported by medical providers—or if all jurors must participate in each question as argued by Hild under Ohio law's "any majority" rule.

According to the Ohio Constitution, civil case verdicts require "the concurrence of not less than three-fourths of the jury." Medical providers assert that plaintiffs must convince six out of eight jurors on all essential elements without piecemeal assembly across different questions.

Hild argues for full jury participation on each question to protect constitutional rights and establish liability when at least six jurors agree on every point.

The court will also hear three additional cases: Adams v. Harris concerning tax value appeals for farmland; Ackman v. Mercy Health West Hospital regarding lawsuit notice rules; and State v. Echols about witness intimidation evidence admissibility.

Oral arguments for these cases will take place on April 9 at 9 a.m., streamed live online via SupremeCourt.Ohio.gov and archived on the Ohio Channel.

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