Horn v. St. Peter's Hospital

Summary

The Montana Supreme Court affirmed judgment as a matter of law for St. Peter’s Hospital after a jury verdict in favor of Eric Horn in a medical negligence action involving an inferior vena cava filter. The Court held that Horn failed to present expert testimony establishing the applicable medical standard of care, breach, and resulting damages, and that manufacturer materials could not substitute for the required expert evidence.

Holdings

1. Judgment as a matter of law was proper because Horn presented no legally sufficient evidence establishing the applicable medical standard of care, breach, and resulting damage.
2. A manufacturer's recommendation or package insert may be relevant evidence for the jury, but standing alone it does not establish the medical standard of care.

Questions Presented

1. Whether the District Court erred in granting judgment as a matter of law for St. Peter's Hospital after the jury returned a verdict for Eric Horn.
2. Whether Horn presented sufficient expert testimony to establish the applicable medical standard of care and its breach in his medical negligence claim.
3. Whether manufacturer information concerning the Optease filter could, standing alone, establish the medical standard of care.

Disposition

affirmed