An Ada County jury found that the injuries sustained by the plaintiff, Carl B. Stiefel, arose out of the willful and reckless misconduct of the defendants, Emergency Medicine of Idaho LLC and one of its emergency department physicians. The jury awarded Mr. Stiefel $13.5 million, the second-largest medical malpractice jury award in Idaho history.
The Background and Allegations
In the early morning of March 29, 2016, Mr. Stiefel’s wife, Colleen Moulton, discovered him on the bathroom floor vomiting and complaining of a severe headache. Based on Mr. Stiefel’s condition, Ms. Moulton called an ambulance, which transported Mr. Stiefel to Emergency Medicine of Idaho LLC (EMI). Mr. Stiefel arrived at the emergency department at approximately 4:12 am.
Within the first eleven minutes of arrival, Mr. Stiefel underwent an examination and reported recent bouts of sinus congestion, nausea, vomiting, dizziness, and ringing in his right ear. Thereafter, Mr. Stiefel underwent a CT scan of the head. The physician that reviewed Mr. Stiefel’s CT scan opined that it showed no acute intracranial process, meaning there were no signs of a stroke or bleeding in the head. Nevertheless, Mr. Stiefel remained in the emergency department, as he complained of still being too dizzy to walk.
Based upon Mr. Stiefel’s complaints, a physician opined that he may have benign positional vertigo and admitted him to the hospital for further evaluation and observation. It took at least three hours for Mr. Stiefel to be transferred from the emergency room to a hospital bed. By the time Mr. Stiefel arrived at the hospital, his healthcare provider found that his condition had worsened, and he had become delirious. Despite being in this condition, it took another four to five hours for Mr. Stiefel to be seen by a doctor.
Eventually, a physician ordered an MRI of Mr. Stiefel’s brain. However, he had to continue to wait as the MRI machine was not available until hours later. The MRI was not performed until 5:50 pm, more than 12 hours after he first presented at EMI.
Mr. Stiefel’s MRI revealed that he was having a stroke and had a torn artery in his neck.
Over the next two days Mr. Stiefel underwent surgery, however, his health worsened. Despite the surgery, Mr. Stiefel suffered from an irreparable brain injury. He spent the next three weeks in between the hospital and a local rehabilitation facility. He was also treated for a case of bacterial meningitis. Currently, Mr. Stiefel has impaired movement and can no longer walk.
In 2018, Mr. Stiefel filed a medical malpractice claim, originally naming various defendants as being willful and reckless in their treatment and care. However, in the years following, all but EMI and the primary physician that treated Mr. Stiefel have settled their claims.
The Defendants’ Response to the Allegations
The defendants remaining at trial, EMI and the primary doctor who treated Mr. Stiefel in the emergency room, asserted that the causes of Mr. Stiefel’s injuries were beyond their responsibility. Therefore, they denied all allegations of responsibility and liability in the case.
According to the defendants, the medical treatment Mr. Stiefel received from the ER doctor was standard for a patient with his medical condition and any alleged injuries were the result of complications, not willful negligence or poor medical care.
The Verdict and Its Significance
The jury found that the primary physician who treated Mr. Stiefel in the emergency department was reckless and willful in failing to meet the standards for medical care, which caused Mr. Stiefel’s injuries.
Given that the jury found that the physician was reckless and willful, rather than merely negligent, in failing to meet the standards for medical care, the statutory cap on non-economic damages did not apply in this case. As such, the jury awarded Mr. Stiefel $13.5 million, the second-largest medical malpractice jury award in Idaho history.
Pursuant to Idaho Code sec. 6-1603, damages for personal injury claims shall not exceed the cap annually set by the Industrial Commission. However, this statutory cap does not apply to causes of action arising out of willful or reckless misconduct.
Plaintiff’s attorney demonstrated that the standard of care provided by EMI and the emergency department physician went beyond negligence and was willful and reckless. Plaintiff’s counsel effectively developed a narrative and relied upon Mr. Stiefel’s continued delayed care to show that EMI and its physician willfully and recklessly failed to meet the appropriate standard of care for a patient with comorbidities similar to that of Mr. Stiefel.
