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Hospital Corp. of Lanier Inc. v. Doster

Any error in the admission of evidence of settlement negotiations between the parties was harmless since defendant stipulated its liability.

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Hospital Corporation of Lanier, Inc. admitted to giving E. B. Wallis an overdose of the drug Demerol during his visit to its hospital. A jury trial to determine causation and damages resulted in a verdict of $863,180 for Wallis.1 On appeal Lanier complains of evidentiary rulings allowing in evidence of its financial condition, evidence of settlement negotiations, and cumulative evidence of liability. We find that no evidence of the corporation’s financial condition or of settlement negotiations was admitted at trial. We further find that the court did not abuse its discretion in allowing a limited amount of evidence of liability to be considered by the jury, as the hospital admitted liability. Accordingly, we affirm.

An appellate court is required to construe the evidence in favor of the verdict. Under this standard of review, the evidence shows that a Lanier nurse mistakenly gave Wallis nine times the amount of Demerol prescribed by the treating physician, which caused Wallis immediately to experience respiratory arrest. As a result, Wallis suffered permanent brain damage. Wallis’s daughters met with Lanier’s CEO to inquire into the accident and to seek financial assistance to help care for their debilitated father. The CEO advised them to obtain legal counsel.

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