Published by Arfaa Law Group
Diagnosing rare medical conditions can present significant challenges. However, healthcare providers are still expected to recognize warning signs, order appropriate testing, and refer patients for additional evaluation when the accepted standard of care requires it. When a patient later suffers catastrophic harm because a serious condition went undiagnosed, the resulting medical malpractice litigation often turns on expert testimony establishing what reasonably competent physicians should have done under the circumstances. A recent Maryland decision illustrates how evidentiary rulings concerning expert opinions and medical literature can shape the outcome of a medical negligence trial. If you or a loved one suffered harm because a healthcare provider failed to diagnose a serious medical condition in a timely manner, you should speak with a Baltimore medical malpractice attorney to discuss your legal options.
Factual and Procedural Setting
Allegedly, the decedent sought medical treatment over a period of approximately two years for symptoms that included shortness of breath, lightheadedness, and other cardiovascular complaints. Multiple healthcare providers evaluated the decedent, underwent cardiac testing, and were hospitalized on more than one occasion. Despite continued treatment, the decedent was never diagnosed with cardiac amyloidosis, a progressive condition caused by abnormal protein deposits in the heart.
Reportedly, the decedent died suddenly in December 2017. An autopsy concluded that the death most likely resulted from an arrhythmia caused by previously undiagnosed cardiac amyloidosis. The decedent’s family subsequently filed a medical malpractice action alleging that the defendants failed to recognize the condition, diagnose it during the years preceding the decedent’s death, and provide treatment that could have extended the decedent’s life. Following a jury trial, the jury found that none of the defendants breached the applicable standard of care. The plaintiffs appealed, challenging several evidentiary and procedural rulings made before and during trial.
Expert Testimony in Medical Malpractice Cases
On appeal, the court reviewed whether the circuit court abused its discretion in limiting expert testimony, excluding certain evidence, refusing to reopen discovery, and preventing an additional witness from testifying. The appellate court emphasized that trial judges possess broad discretion when managing discovery and determining the admissibility of expert testimony and evidence, particularly in complex medical malpractice cases.
A significant issue involved the plaintiffs’ cardiology expert, who intended to testify that prescribing a particular medication before it received FDA approval represented the applicable standard of care during the relevant treatment period.
Applying Maryland’s Daubert-Rochkind framework, the trial court determined that the expert failed to demonstrate the reliability of that opinion because it was unsupported by peer-reviewed literature, lacked evidence of general acceptance within the medical community during the relevant years, and relied primarily on the expert’s own conclusions. The court agreed that Maryland law requires more than an expert’s personal belief to establish the applicable standard of care and affirmed the exclusion of that portion of the testimony.
The court also upheld the exclusion of a medical journal article published shortly before the decedent’s death. Because medical malpractice claims are evaluated based on the standard of care existing when the alleged negligence occurred, the court concluded that a publication released after most of the relevant treatment period could not reliably establish what reasonably competent physicians should have known during the earlier years at issue.
The court further observed that the plaintiffs’ expert remained free to testify regarding the standard of care based on training and clinical experience even without introducing the article itself. Finally, the court affirmed the jury’s verdict for the defense, finding no abuse of discretion in the trial court’s evidentiary rulings or in its management of discovery.
Discuss Your Potential Case with a Knowledgeable Medical Malpractice Baltimore Attorney
If you believe you or a loved one suffered preventable harm because a serious medical condition was not timely diagnosed or treated, the knowledgeable Baltimore medical malpractice lawyers at Arfaa Law Group can review your medical records, evaluate the strengths of your claim, and help you determine the most effective course of action. Call Arfaa Law Group at (410) 889-1850 or contact the firm through its online form to schedule a confidential and free consultation.