Pa. Court Reinstates Legal Malpractice Suit Over Vacated $735K Med Mal Verdict
Superior Court Judge Mary Jane Bowes said that while two suits may have stemmed from the same procedure and involved the same doctor, they involved two different sponges that were discovered years apart.
April 01, 2020 at 04:23 PM
5 minute read
A Pennsylvania appeals court has reinstated a legal malpractice suit against a midstate attorney and his former firm over a more than $700,000 personal injury verdict that was later lost on appeal.
The state Superior Court on Monday reversed a Dauphin County Court of Common Pleas judge's decision to toss the legal malpractice lawsuit Garman v. Angino on summary judgment. The appellate court's 2-1 holding reinstates claims against Richard Angino and his former firm Angino and Rovner.
Judge Mary Jane Bowes wrote the majority opinion and was joined by Judge Judith Olson. Judge Victor Stabile dissented.
According to Bowes, the case presents an "unusual" set of facts involving two lawsuits that were filed several years apart, each raising claims related to a 1993 cesarean section that plaintiff Kelly Garman underwent. Both lawsuits also resulted in plaintiffs verdicts, but the second one was later dismissed on appeal for being brought outside the statute of limitations.
After the plaintiffs filed their legal malpractice suit, the Dauphin County court eventually determined that, despite the favorable verdicts at trial, the second lawsuit would have been further barred by collateral estoppel, res judicata and the one-satisfaction rule, and so without a viable lawsuit, the legal malpractice claims against Angino and his former firm should have failed as well.
Bowes, however, said that while two suits may have stemmed from the same procedure and involved the same doctor, they involved two different sponges that were discovered years apart. Finding that the Garmans still could have sued the doctor if the claims had been brought in time, Bowes determined the legal malpractice claims should be able to proceed.
"We do not believe the Garman I jury could have contemplated a separate, yet-to-be-discovered sponge and attendant bowel injury when it fashioned its damage award for future pain and suffering," Bowes said. "Indeed, such injuries and damages were unforeseeable and speculative."
According to Bowes, Angino and his former firm represented Garman in both lawsuits stemming from the 1993 procedure. The first suit was brought against Dr. Sohael Raschid and Chambersburg Hospital, after a 1997 procedure to remove what was thought to be a painful fibroid discovered that a sponge had been left in Garman's abdomen. The case resulted in a verdict of more than $521,000.
Garman underwent another cesarean section in 1999, and again began experiencing abdominal pain afterward, Bowes said. A 2006 CT scan showed another foreign body in her abdomen, which turned out to be another sponge.
Angino and his firm sued several doctors involved in the 1999 and 1997 procedures, as well as Raschid and Chambersburg Hospital, who were involved in the 1997 removal procedure. They argued the defendants either negligently left the sponge in during those procedures, or failed to timely discover and remove it. Bowes said that during discovery more than three years after the second sponge was discovered, an expert opined that Raschid may have left that sponge in her as well during the 1993 surgery. The trial court allowed Angino and his firm to amend the complaint with additional claims against Raschid and Chambersburg Hospital, alleging additional negligence in connection with the 1993 procedure.
The second suit came to a $735,000 verdict, with 65% liability against Chambersburg Hospital and 35% against Raschid. The jury further determined the sponge had been placed there during the 1993 surgery. The Superior Court, however, vacated the award on appeal, finding the court erred when it allowed the plaintiffs to amend their complaint outside the statute of limitations.
The Garmans subsequently filed their medical malpractice action against Angino and his former firm, contending that they would still have the $735,000 verdict if the claims had been brought in time. In challenging the malpractice suit, Angino and his firm contended that the Garmans still would not have had a second case over the 1993 procedure, given that there had already been a trial adjudicating those claims.
Although the Dauphin County court agreed with the attorneys' argument, Bowes said that, among other things, the fact that the second sponge wasn't even found by the time that jury was deliberating showed that the first jury was contemplating entirely different damages.
"The payment of the judgment in Garman I represented satisfaction for the injury and damages attributed only to the first sponge, including any future injuries or damages flowing from the negligent retention of that sponge," she said. "The injuries and damages resulting from the second sponge are separate and severable."
Neither Clifford Haines of Haines & Associates, who represents the Garmans, nor Louis Isaacsohn of Wilson, Elser, Moskowitz, Edelman & Dicker, who represents Angino and his former firm, returned a call seeking comment.
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllPittsburgh Judge Rules Loan Company's Online Arbitration Agreement Unenforceable
3 minute readPhila. Jury Awards $15M to Woman Who Slipped on Apartment Building Stairs
4 minute readPa. Hospital Agrees to $16M Settlement Following High Schooler's Improper Discharge
4 minute readLaw Firms Mentioned
Trending Stories
- 1Decision of the Day: Judge Reduces $287M Jury Verdict Against Harley-Davidson in Wrongful Death Suit
- 2Kirkland to Covington: 2024's International Chart Toppers and Award Winners
- 3Decision of the Day: Judge Denies Summary Judgment Motions in Suit by Runner Injured in Brooklyn Bridge Park
- 4KISS, Profit Motive and Foreign Currency Contracts
- 512 Days of … Web Analytics
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250