Young v. United States

Young v. United States,
2003 U.S.Dist. LEXIS 25238
W.D. Texas; July 11, 2003

  • Alleged injury or harm: third-degree perineum tear during delivery of baby, and subsequent injuries
  • Theories of negligent conduct: failure to perform an episiotomy, to give an enema during labor or prior to delivery, to administer pre-emptive antibiotics in repairing a laceration breakdown, and to use chromic stitches
  • Judgment: Defendant is not liable.

The plaintiff, Kalen K. Young, experienced a third-degree perineal tear during the delivery of her baby, “which involves either a partial or complete tear through the muscle that goes around the rectum.” (Decision, para. 49.) She and her husband Dr. Russell John Young, III, alleged that her injuries were caused by one or more of the following: negligent failure to perform an episiotomy, negligent failure to give an enema during labor or prior to delivery, negligent failure to administer pre-emptive antibiotics in repairing a laceration breakdown, and negligent failure to use chromic stitches.

The Court, deciding the case under the Federal Tort Claims Act and applying the substantive law of California, held that:

  • “There was no negligence in not performing an episiotomy with this forceps delivery.” (Decision, “Conclusions of Law,” para. 14)
  • ”[P]laintiffs have failed to prove by the greater weight of evidence that the failure to cut an episiotomy was a cause in fact of Mur. [sic] Young’s subsequent injuries.” (Decision, “Findings of Fact,” para. 79)
  • “Plaintiffs have failed to establish the necessary standard of care [regarding the treatment for constipation] or to show the reliability of their expert’s opinion.” (Decision, “Findings of Fact,” para. 35)
  • “Mrs. Young’s constipation was appropriately addressed.” (Decision, “Findings of Fact,” para. 30)
  • “Causation was not proven within a reasonable medical probability on the treating physician’s decision to forgo treatment with antibiotics when there was no evidence of an infection in the preoperative report when the first breakdown repair occurred.” (Decision, “Conclusions of Law,” para. 15)
  • “While there may have been more than one method to repair the first or second breakdown of the suturing, the alternative methods actually employed in trying to close the site in no way constituted negligence on the occasions in question based on the greater weight of the competent evidence.” (Decision, “Conclusions of Law,” para. 15)

The reasoning of the Court exhibits the following features:

    • With regard to establishing the medical standard of care, the Court applied California’s Locality Rule;
    • With regard to the episiotomy, the Court employed a “best judgment” rule in the face of two schools of thought;
    • With regard to the pre-emptive antibiotics, the Court engaged in Modus Ponens reasoning; and
    • The Court engaged in cause-in-fact reasoning with respect to the failure to perform an episiotomy.

Open an HTML copy of the reasoning.

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