Field v. Trigg County Hospital

Tina Field went to the emergency room at Trigg County Hospital, Inc. (Trigg) (defendant) to be treated for a copperhead snake bite in her foot. Dr. William Anderson (defendant) determined that the snake had released venom into the bite. Anderson gave Field a tetanus shot and fluids and checked on her every few hours. However, Anderson did not give Field any antivenin, a serum that counteracts certain poisons, including some snake venom. Field’s foot was swollen and became progressively colder and bluer in color. After approximately 20 hours of treatment, Field’s foot no longer had a pulse. About three hours later, Anderson called the emergency room at Vanderbilt University Medical Center (Vanderbilt) and spoke to an emergency-room doctor and a toxicologist. Anderson then continued his same course of treatment. Field never regained a pulse in her foot and eventually had part of her leg amputated. Field sued Trigg and Anderson for medical malpractice, but Trigg settled. At trial, the court allowed Anderson to testify about his conversation with the two Vanderbilt doctors. Anderson could not identify either doctor by name, but he testified that both doctors told him that he was acting appropriately, that he was doing everything they would do, and that neither of them would give a patient antivenin for a copperhead snake bite. The court instructed the jury that it could consider the conversation in its deliberations but not the validity of the Vanderbilt doctors’ advice. The jury found that Anderson did not commit medical malpractice. The trial court denied Field’s request for a new trial, and Field appealed. On appeal, Field argued that Anderson’s testimony about the out-of-court statements by the unidentified Vanderbilt doctors should have been excluded as inadmissible hearsay. Anderson claimed that the testimony was not hearsay because it was offered to show his act of consulting with other doctors, not for the truth of the other doctors’ statements.