Hill v. Rhinehart

45 N.E.3d 427 (2015)

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Nature of the Case

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Facts

P was admitted to Parkview Hospital for a cardiac catheterization related to angina pain. Dr. Ryan, a board-certified cardiologist, performed the procedure, which revealed severe coronary artery disease with multiple blockages of two main coronary arteries. Dr. Ryan recommended immediate coronary artery bypass surgery. Dr. Lloyd, a board-certified vascular surgeon, executed Hill's coronary bypass surgery. The surgery was pronounced a success, and P was moved into the intensive care unit for recovery. P manifested numerous complications. Dr. Ryan suspected P to be suffering from Heparin-Induced Thrombocytopenia (HIT), which is a rare 'immune mediated response to the presence of the Heparin antigen in the body.' P was not administered a non-Heparin anticoagulant as a replacement medicine, even though a non-Heparin option, Refludan, was available. Unbeknownst to Dr. Ryan, Hill continued to receive a minimal dose of Heparin because of the Hospital's protocol that prescribed 'Heparin flushes' of the IV lines. The anticipated bounce in platelet counts never occurred. P developed life-threatening complications. The swelling in P's left arm worsened, with his hand becoming 'cool and blue.' Dr. Csicsko, a board-certified cardiovascular surgeon, discovered that P had continued to receive Heparin through the flushing of his IV lines and discontinued the protocol. P's limbs were necrosing. Dr. Rhinehart, a hematologist, was consulted and diagnosed Acute Respiratory Distress Syndrome, sepsis, DIC. Dr. Rhinehart immediately ordered a 5,000-unit bolus of Heparin, to be administered. Eventually, Dr. Rhinehart ordered the administration of Refludan 'to prevent further clotting from occurring.' Dr. Goertzen amputated the left arm just below the elbow and the right leg above the knee. P was eventually released to the Rehabilitation Institute of Chicago where he received in-patient physical therapy before returning home in early April 2000. P filed a proposed Complaint for medical malpractice with the Indiana Department of Insurance alleging that Dr. Ryan, Drs. Lloyd and Csicsko, and Dr. Rhinehart violated their respective standards of care in providing Hill post-surgical care, resulting in the loss of three limbs. At the conclusion of P's case in chief, all four physicians moved for judgment on the evidence, asserting that P had failed to present any evidence establishing that the doctors had caused a separate and distinct injury from the injuries already compensated. Two doctors were granted the motion. The jury returned a verdict in favor of Drs. Ryan and Rhinehart. P appealed.