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Bowman v. Gronstedt

3/13/2002

d the applicable standard of care by discharging Wendy from the hospital on October 2 and his discharge plan for Wendy was also substandard. Dr. Luchins testified Dr. Gronstedt's "plan" did nothing to treat Wendy's mental illness, stating, "You become bipolar because of genetic or biological constitution that makes you bipolar, and you don't get cured from bipolar illness by getting divorced." Dr. Luchins further testified Dr. Lee breached the applicable standard of care because she released Wendy on October 5, 1996, and failed to consult Dr. Gronstedt to ensure that Wendy received the follow-up treatment recommended.


In addition, Dr. Luchins testified a possible cause of Wendy's death was starvation. He noted Wendy was purging herself, either by vomiting or using laxatives, and this would have changed her body chemistry, including a loss of electrolytes. He further testified:


The other abnormality that Wendy has that may have endangered her life was that she drank large amounts of water, and if you drink a lot of water, you can get what's called water intoxication, intoxicated where you - you change your body chemistry and your initial signs are then confusion and delirium, and where you don't know where you are, don't know what you're doing. A little bit similar to what actually Wendy was showing. And if it gets more severe, you change your body chemistry to the point that you get seizures, and if it continues to get more severe, you actually can stop your heart. You just change your body chemistry, and this is - a water intoxication is a fairly common symptom in severe psychiatric illness.


And I don't know if that was what caused Wendy's death, but it's a possibility.


Lastly, Dr. Luchins testified Wendy may have suffered from polydipsia, a psychiatric condition which occurs when a person drinks an excessive amount of water. He testified that because Wendy was purging, she could become water intoxicated more quickly, with a resulting risk of seizures or death.


In their motions for directed verdict, the defendant doctors argued that Bowman's evidence was as a matter of law insufficient to establish a causal connection between any theory of malpractice and Wendy's death. In a ruling granting the doctors' motions, the court said, "I would grant the defendants' Motion for Directed Verdict on the lack of proof as to the proximate cause of death being related to the conduct of either of the defendants." As a result, Bowman's claims were dismissed resulting in this appeal.


II. Scope of Review.


We review a district court's grant or denial of a motion for directed verdict for correction of errors of law. Iowa R. App. P. 6.4. We view the evidence in the light most favorable to the nonmoving party and afford them every legitimate inference we can reasonably deduce from the evidence. Nesbit v. Myers, 576 N.W.2d 613, 614 (Iowa Ct. App. 1998). A motion for directed verdict should be denied if there is substantial evidence to support the plaintiff's claim. Hasselman v. Hasselman, 596 N.W.2d 541, 545 (Iowa 1999). Evidence is substantial when a reasonable mind would accept it as adequate to reach a conclusion. Id.


III. The Merits.


A medical malpractice claim premised on negligence requires proof of an affirmative act of negligence, lack of skill or care, or failure to give careful or proper attention to a patient. Lagerpusch v. Lindley, 253 Iowa 1033, 1037, 115 N.W.2d 207, 210 (1962). A prima facie medical malpractice case requires proof establishing the applicable standard of care, the defendant's breach of the applicable standard of care, and a causal relationship between the defendant's breach and the plaintif

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