Ruiz v. Tenet Hialeah Healthsystem, Inc.Annotate this Case
The Supreme Court quashed the decision of the Third District Court of Appeal affirming the entry of a directed verdict in favor of Arturo Lorenzo, M.D. in this medical malpractice action, holding that the decision below was inconsistent with precedent regarding the proximate causation standard.
In granting a directed verdict in favor of Dr. Lorenzo, an anesthesiologist, the trial court held that, even assuming Dr. Lorenzo was negligent in his care of the patient in this case, he did nothing more than place her in a position to be injured by the independent actions of surgeons. The district court affirmed, holding that no competent, substantial evidence in the record would allow a reasonable factfinder to conclude that Dr. Lorenzo was the “primary cause” of the patient’s death. The Supreme Court reversed and remanded, holding (1) the district court erred by equating the proximate cause of an injury with the primary cause of an injury; and (2) while Dr. Lorenzo’s conduct was not eh primary cause of the patient’s death, he may nonetheless be liable for his part in it if his failure to read and report abnormal test results substantially contributed to causing it.