SEPTEMBER 2020 BAR BULLETIN | Page 11

PERSONAL INJURY CORNER DISCOVERY OF MEDICAL MALPRACTICE CLAIM UNDER STATUTE OF LIMITATIONS TED BABBITT Florida Statute 95.11(4)(b) states: “An action for medical malpractice shall be commenced within 2 years from the time the incident giving rise to the action occurred or within 2 years from the time the incident is discovered, or should have been discovered with the exercise of due diligence; however, in no event shall the action be commenced later than 4 years…” Mobley v. Homestead Hospital, Inc., 45 Fla.L.Weekly D2 (Fla. 3d DCA December 26, 2019), was an appeal from an order granting a summary judgment on the issue of the statute of limitations in a complex medical malpractice case involving the delivery of a baby born with a neurologic injury. The child was born on September 16, 2009, and a Notice of Intent was filed on July 22, 2013, a few months short of the 4 year period described in the statute. Plaintiffs claimed that they had no knowledge of the potential for a malpractice case until November of 2012 when they were told by a doctor and his nurse that the child’s diagnosis of spastic cerebral palsy might well be related to the delivery of the child. Prior to that time, the child was seen by a number of doctors all of whom indicated the child’s delayed progress was either related to a genetic issue or was unknown. The Hospital relied for its Motion for Summary Judgment on the fact that the Plaintiffs hired an attorney who requested medical records pursuant to Florida Statute 766.204. The Florida Supreme Court explained in Tanner v. Hartog, 618 So. 2d 177, 181- 82 (Fla. 1993) how to calculate the start of the discovery portion of the statute of limitations: “We hold that the knowledge of the injury as referred to in the rule as triggering the statute of limitations means not only knowledge of the injury but also knowledge that there is a reasonable possibility that the injury was caused by medical malpractice. The nature of the injury, standing alone, may be such that it communicates the possibility of medical negligence, in which event the statute of limitations will immediately begin to run upon discovery of the injury itself. On the other hand, if the injury is such that it is likely to have occurred from natural causes, the statute will not begin to run until such time as there is reason to believe that medical malpractice may possibly have occurred.” According to Cowen v. Cooper, 20 So. 3d 453, 455-56, (Fla. 4th DCA 2009), knowledge of the medical condition alone is not enough to determine when the Statute of Limitations accrues. The Third District, in Mobley, in overturning the summary judgment entered for the Hospital, held that: “In the Mobleys’ case, the issue revolves around the date when Mrs. Mobley had knowledge that there was a reasonable possibility that Tavarion’s injuries resulted not from a natural cause, but from medical malpractice. This is the date that the statute of limitations begins to run. Florida courts have held that this determination of when a person knew or reasonably should have known of the possibility of medical malpractice is ‘fact-specific and within the province of the jury, not the trial judge’. Id. at 456. Florida law is clear on this issue. Gonzalez v. Tracy, 994 So. 2d 402, 405 (Fla.3d DCA 2008). Suspecting wrongdoing has been held not to be enough. Thomas v. Lopez, 982 So. 2d 64, 68 (Fla. 5th DCA 2008).” In overturning the summary judgment, the Mobley Court relied on Baxter v. Northrup, 128 So. 3d 908 (Fla. 5th DCA 2013), which at 910, 912 held: "It is difficult to envision how a lay person can be charged with knowledge that particular symptoms suggest an act of negligence when medical professionals, who scrutinize the case with the clarity of hindsight, conclude that the symptoms are the product of unexplained, natural causes. ... Though [the patient’s] suspicions might have been mounting throughout the period following his surgery, this alone does nothing to pinpoint, as a matter of law, a definitive start date for the commencement of the running of the statute. This is a question for the jury, not appropriate for summary judgment.” The Third District thus held that a genuine issue of material fact existed as to when the Plaintiff acquired knowledge that there was a reasonable possibility that her child’s injuries were caused by medical malpractice and that, therefore, the Trial Court improperly granted a summary judgment. NOTE: BECAUSE A NUMBER OF PEOPLE HAVE REQUESTED COPIES OF PAST ARTICLES, A COMPILATION OF THESE ARTICLES IS NOW AVAILABLE TO MEMBERS OF THE PALM BEACH COUNTY BAR ASSOCIATION, FREE OF CHARGE, BY CALLING (561) 684-2500. 7.28.20 Personal Injury Seminar The Personal Injury CLE: Unique Issues in Transportation Cases The Personal Injury CLE committee held a live webinar via Zoom on Tuesday, July 28, 2020. Featuring business sponsor Ceara Goodnow from Global Engineering Scientific Solutions, David C. Prather, Esq., Rebecca Brock, Esq., Poorad Razavi, Esq., Rachel Studley, Esq., Michael Smith, Esq., David Drahos, Esq., Peter Hunt, Esq., and Geoff Probst all spoke. CLE recording is now available for MP3 or CD purchase at https://cle.palmbeachbar.org. PBCBA BAR BULLETIN 11