Montgomery Health Care Facility, Inc. v. Ballard

Edna Stovall was a patient at Montgomery Health Care Facility, Inc. (Montgomery Health) (defendant), a nursing home owned and operated by First American Health Care, Inc. (First American) (defendant). First American exercised daily control over Montgomery Health’s operations. Stovall was admitted to Montgomery Health in February 1985, suffering from several serious health conditions. Stovall did not have any bedsores upon admission. Bedsores are pressure sores caused by the compression of tissue between bones and supportive surfaces, like beds. Pressure sores start at the skin level but can reach into the muscles and become fatally infected. Bedsores are prevented by regularly monitoring, turning, and exercising the patient. Bedsores are treated with sterile wound care and by keeping the patient clean. Stovall developed her first bedsore a week after admission to Montgomery Health. Over the next year, Stovall required multiple surgical interventions to treat seriously infected bedsores. Stovall ultimately died from complications related to the infected bedsores. Ella Ballard (plaintiff), the administrator of Stovall’s estate, sued Montgomery Health and First American for negligence, arguing that their neglect proximately caused Stovall’s death. At trial, Stovall’s children testified that Montgomery Health neglected Stovall’s personal hygiene, failed to properly clean and treat Stovall’s bedsores, and failed to regularly turn and exercise Stovall. The trial court admitted into evidence complaint reports submitted to the Alabama Department of Public Health (DPH) stating that Montgomery Health was understaffed, that numerous patients suffered from dangerously infected bedsores, that patients were not monitored or exercised properly, and that staff members lacked training in infection management. The jury awarded Ballard $2 million in damages. Montgomery Health and First American appealed, arguing that (1) the DPH complaint reports were inadmissible; and (2) First American was not liable for Montgomery Health’s negligence.