In Maryland, determining liability in medical malpractice cases often involves a detailed examination of the actions of all parties involved. In some cases, this may include an assessment of the potential liability of third-party practitioners. This was demonstrated in an opinion recently issued by a Maryland court that highlights the issue of third-party negligence and its potential impact on a plaintiff’s right to recover in a medical malpractice case. If you suffered harm due to medical negligence, consulting a Baltimore medical malpractice attorney can help you understand your rights and options.
History of the Case
It is reported that the plaintiff’s child was born with severe injuries, including cerebral palsy, allegedly due to the delay in performing a Caesarean section at a Maryland hospital. The child’s parents filed a medical malpractice claim against the hospital, asserting that its delay in acting caused preventable injuries. The hospital, in turn, argued that a nurse midwife, who had been assisting the mother prior to her arrival at the hospital, was solely responsible for the injuries.
Reportedly, the midwife engaged in multiple actions that were alleged to deviate from accepted standards of care, including administering Pitocin without adequate monitoring and improperly performing an episiotomy. These interventions, according to the hospital, led to complications that necessitated emergency care upon the mother’s arrival.
Allegedly, at trial, the parents moved to exclude any evidence regarding the midwife’s standard of care or alleged breaches. The trial court granted the motion, limiting the hospital’s ability to present evidence that the midwife’s actions were the sole cause of the injuries. The jury ultimately awarded the plaintiffs substantial damages, including $26 million in non-economic damages, though the award was later reduced in accordance with Maryland’s cap on such damages. The hospital appealed.
Admissibility of Evidence on Third-Party Negligence
On appeal, the hospital argued that excluding evidence of the midwife’s negligence unfairly limited its defense. The court began its analysis by emphasizing that Maryland law allows evidence of third-party negligence to be introduced when it is relevant to the determination of causation.
In medical malpractice cases, the causation element often involves multiple contributing factors, and evidence of other healthcare providers’ conduct can provide necessary context to evaluate the sequence of events leading to the injury. The defendants maintained that the midwife’s actions constituted a breach of the standard of care, independent of any negligence by the hospital staff, and were therefore a superseding cause of the child’s injuries.
In its ruling, the appellate court clarified that Maryland law does not require defendants to establish that a third party is liable to avoid responsibility entirely. Instead, defendants can present evidence of third-party negligence to mitigate their own liability by demonstrating that the harm was caused by an intervening factor outside of their control. The exclusion of this evidence, the court reasoned, denied the defendants a meaningful opportunity to argue their case and left the jury with an incomplete understanding of the events leading to the injury.
Ultimately, the court held that the trial court’s decision to grant the motion in limine constituted a significant error that undermined the fairness of the trial. The exclusion of evidence regarding the midwife’s standard of care, combined with the jury’s inability to consider her actions, warranted reversal of the judgment and a remand for a new trial.
Speak with a Trusted Baltimore Medical Malpractice Lawyer
If you believe you were injured due to medical negligence, it is crucial to have experienced legal representation to help you navigate the complexities of Maryland medical malpractice law. The trusted Baltimore medical malpractice attorneys at Arfaa Law Group can assess your case, identify all potentially liable parties, and advocate on your behalf to pursue the compensation you deserve. Call us at (410) 889-1850 or fill out our online form to schedule a consultation.