Wrongful-death claim based on allegations of medical malpractice; Causation; Expert testimony; St. Joseph Mercy Hospital (SJM); Internal Medical Specialists (IMS); Personal representative (PR)

In this medical malpractice case, the court affirmed the trial court’s orders granting summary disposition in favor of the SJM and IMS defendants. Plaintiff-PR filed a wrongful-death claim grounded in medical malpractice. She argued that the trial court erred by holding that she did not present evidence sufficient to establish the element of causation. As to the SJM defendants, the court held that there was no dispute that the injury to the decedent’s (Patterson) “arm was caused by an extravasation, and the picture of Patterson’s injury leaves no reasonable room to doubt that it was significant. Michigan medical malpractice jurisprudence requires plaintiff to have expert medical testimony to establish that the nurses’ alleged negligence caused the worsening of Patterson’s extravasation injury and the resultant pain and suffering. In the absence of expert testimony to establish causation, plaintiff cannot show that the trial court erred by granting” the SJM defendants summary disposition. As to the IMS defendants, plaintiff did not establish that, but-for defendant-Dr. Dreslinski’s “resumption of Patterson’s Xarelto prescription, Patterson would not have suffered internal bleeding on January 25. Without establishing that Dr. Dreslinski committed medical malpractice, plaintiff cannot sustain a wrongful-death action against the IMS defendants.” Thus, the court concluded “that the trial court did not err by granting summary disposition of plaintiff’s claims in favor of the IMS defendants.”