Johnson v. Riverdale Anesthesia Associates
Supreme Court of Georgia
563 S.E.2d 431 (2002)
Clair Johnson (Clair) died after a severe reaction to anesthesia during surgery deprived her of oxygen. Clair’s husband Donald Johnson and the administratrix of her estate (collectively, Johnson) (plaintiffs) sued Clair’s anesthesiologist, Lawhead, and Lawhead’s employer, Riverdale Anesthesia Associates (collectively, Anesthesia Associates) (defendants) in a Georgia state court. Johnson alleged that Anesthesia Associates’ failure to “preoxygenate” Clair before surgery—which would have supplied her with a reserve of oxygen in the event that her supply were disrupted—was a breach of the standard of care constituting medical malpractice. Both parties relied upon medical expert witnesses. Johnson planned to question Anesthesia Associates’ expert, Caplan, about his personal practice of preoxygenating patients. Evidence showed that Caplan would have preoxygenated Clair had she been his patient. Anesthesia Associates moved in limine to preclude that line of questioning by Johnson. The trial court sustained the motion. A jury found in favor of Anesthesia Associates, and an appellate court affirmed the judgment. Johnson appealed.
Rule of Law
Holding and Reasoning (Sears, J.)
Dissent (Carley, J.)
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