Supreme Court Boosts Power of Trial Judge in Med-Mal Reversal
"The trial court's approval of the verdict creates a presumption of correctness which is not to be disturbed absent compelling evidence," Justice Charlie Bethel said.
October 07, 2019 at 04:41 PM
4 minute read
The Georgia Supreme Court gave a nod Monday to the power of the trial judge and jury.
Georgia's high court reversed its intermediate appellate court Monday over the legal standard for reviewing a medical malpractice case that began with what the patient described as the worst headache of her life. That headache 7½ years ago led to catastrophic injuries resulting from an undiagnosed ruptured brain aneurysm. Lawyers have been fighting ever since over the damages. The Georgia Supreme Court sent the case back to the Georgia Court of Appeals for another look.
"We conclude that the Court of Appeals applied the wrong standard in reviewing the trial court's decision, and so we vacate the judgment and remand the case with direction to apply the standard set forth in this opinion," Justice Charles Bethel wrote.
The unanimous opinion sets aside the Court of Appeals ruling that Shawn Evans is entitled to a new trial for his wife, Janice Evans. The high court opinion doesn't say they won't get a new trial. But it says the intermediate court will have to look at the case another way.
The DeKalb County State Court jury awarded nearly $1.2 million for past medical expenses and more than $67,000 for the husband's loss of consortium claim, but nothing for future medical expenses—even though she is permanently disabled and unable to care for herself. Plus, the jury apportioned only 51% of the fault to the defendant, Rockdale Hospital, cutting her award to just under $645,000. The couple asked for a new damages-only trial. The judge refused, leading to the appeal.
The Court of Appeals ordered a new trial in August 2018, ruling the half-million dollar verdict, which included past medical expenses but nothing for future expenses, or pain and suffering, was so meager as to "shock the conscience."
But that new trial is now uncertain with Monday's high court opinion.
Bethel focused on the difference between a trial judge's authority and that of an appellate court.
"As we have previously held, OCGA § 51-12-12 allows the trial court to interfere with a jury verdict in two opposite situations—where the award is so inadequate or so excessive as to be contrary to the preponderance of the evidence," Bethel wrote. "Moreover, an excessive or inadequate verdict is a mistake of fact rather than of law and addresses itself to the discretion of the trial judge, who, like the jury, saw the witnesses and heard the testimony. In fact, the trial court's approval of the verdict creates a presumption of correctness which is not to be disturbed absent compelling evidence."
The appellate judges weren't at the trial, Bethel noted.
"Appellate review, by contrast, involves a different analysis," Bethel said. "While trial courts have discretionary powers to set aside verdicts based on an analysis of the evidence they observed as described in OCGA § 51-12-12, appellate review is confined to the question of whether the trial court abused its discretion in deciding the motion for new trial on this ground."
Bethel said appellate judges are to "ensure that the trial court actually exercised its discretion in reviewing the award." But, he added, "an appellate court does not have the broad discretionary powers invested in trial courts to set aside verdicts, and when the trial court before whom the witnesses appeared had the opportunity of personally observing the witnesses has approved the verdict, this court is without power to interfere unless it is clear from the record that the verdict of the jury was prejudiced or biased or was procured by corrupt means."
In the ruling, the justices said they "must disapprove" of at least one of their previous holdings and a long list of previous Court of Appeals decisions that allow for a more expansive appellate review.
Lloyd Bell of the Bell Law Firm represents Shawn and Janice Evans. "We are still reviewing the opinion with our appellate team and have not yet decided on our next steps," Bell said.
Dan Huff and R. Page Powell Jr. of Huff Powell represent Rockdale Hospital.
Powell said Monday that while the Court of Appeals could still order a new trial, the strict standard for appellate review the Supreme Court highlighted will make it harder to do so. Bethel's ruling, Powell said, underscores the power of the trial judge and jury. He added, "It's really an affirmation of the sanctity of that system."
The case is Rockdale Hospital v. Evans, No. S18G1189.
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