Georgia court finds no requirement for an employee to intervene when higher trained first aid providers are present.

Sixteen-year-old collapsed at the defendant YMCA. A sheriff deputy and EMT provided CPR. Court held that the congenital heart disease had no causal connection to the Y’s negligence if there was any. Court also held the Y was not negligent because the employees did nothing, because higher trained medical personnel were already attending to the victim.

Goins et al. v. The Family Y et al. 326 Ga. App. 522; 757 S.E.2d 146; 2014 Ga. App. LEXIS 216; 2014 Fulton County D. Rep. 909

State: Georgia, Court of Appeals

Plaintiff: James and Jennifer Goins

Defendant: The Family YMCA

Plaintiff Claims: negligence and fraud

Defendant Defenses: No duty and proximate causation

Holding: for the defendant

Year: 2014

The plaintiffs are the parents of a sixteen-year-old who died walking on a treadmill at the defendant Family Y (YMCA). It was determined the deceased died from congenital heart disease.

The plaintiff’s brought their son to the YMCA to get ready for baseball season and to lose some weight. They chose the Y because it was a safe and positive environment with adequate well trained employees “on hand at all times and that these employees would have access to life-saving equipment and would know how to use it.”

(This is an example of looking at the website and brochure post-accident and looking for information or is this why they picked the Y?)

An employee of the Y saw the deceased fall and immediately called 911. She did not go to the deceased because she said there was a sheriff’s deputy who was a first responder and had another first aid training attending to the deceased. Soon thereafter, an EMT also assisted the deceased.

The parents, plaintiff’s, sued the defendant because their son:

…was under the “personal care” of a Y employee who had no CPR or first aid training, in spite of representations made by the fitness center. The Goins also claimed that the Y employees stood around and did nothing after Brant collapsed. The complaint alleged that the AED or defibrillator was locked away and not available in case of emergency. There was also a fraud count in which the Goins contended that the Y made misrepresentations to them that led them to believe that the Y was a “safe and positive” environment for their son.

The trial court dismissed their claims, and the plaintiff’s appealed.

Analysis: making sense of the law based on these facts.

The first issue was whether there was a duty to render first aid and whether the representations that the Y misled the parents. The court first outlined the requirements to prove negligence in Georgia.

The essential elements of a negligence claim are the existence of a legal duty; breach of that duty; a causal connection between the defendant’s conduct and the plaintiff’s injury; and damages. Thus, the threshold issue in a negligence action is whether and to what extent the defendant owes a legal duty to the plaintiff. This issue is a question of law.

The plaintiffs argued there was a special relationship between themselves and the Y because the Y assumed a special duty to supervise minor children. The appellate court shot down that argument with one sentence. “Brant Goins was 16 years of age and the only duty undertaken by the Y was to provide him with a personal trainer to help him lose weight. It is undisputed that this is what occurred.”

The second issue on appeal was the negligence claim. As stated above to prove negligence, there must be a connection between the injury and the breach of the duty. Here the duty was alleged to be a lack of training, as advertised by the Y., However, the court could not find a connection. CPR would not have saved the deceased’s life and the people attempting to do so were better trained then the employees. “…the [plaintiff’s] cannot show a causal connection between Mason’s or any other employee’s lack of CPR training and Brant Goins’ death.” A casual connection is less than the proximate causation required to prove negligence.

It is undisputed that there was an emergency medical technician, and a deputy sheriff trained as a first-responder present at the time of Brant’s collapse. There would have been no reason for a Y employee to interfere with the care being given by the two qualified first responders.

The final issue was the fraud claim. The fraud claim was based on the allegations that the Y promised the plaintiff’s that the YMCA was a safe and positive environment and that there would be adequate and well-trained employees, and the employees would have access to life-saving equipment.

There was not argument that this did not occur. The plaintiff’s then tried to tie together the fact these things did not occur and that because their son had died, proving negligence.  (The absence of facts does not prove a point in most cases and those facts that exist must link to each other in a legal way.) However, the court did not find this to be proved either.

Even assuming that the Goins could establish the other elements of their fraud claim, they can show no damage as the result of this claimed fraud. The EMT and the deputy were clearly the most highly trained people present in administering CPR. Neither called for a defibrillator and both testified that a defibrillator, would not be used on someone with a pulse who was still breathing.

Not brought up in the decision on this argument was proximate causation. There was no connection between the facts that if the Y had not done any of the issues pled in the fraud that the misrepresentation had anything to do with the death of their son.

The appellate court affirmed the lower court’s decision.

So Now What?

First, it is great to have a court require a special relationship or acceptance of a duty that can be proved, not just argued and based on trying to tie loose facts together. The Y’s acceptance of the deceased minor to provide a trainer came with no other requirements, and the Y did nothing to create additional duties which it could be held too.

This is critical that in bringing in business, you don’t make promises that either you can’t complete or that may come back to haunt you.

Second, although specifically identified, the issue of higher medical care prevailed. I’ve never seen this issue argued in a case, that the person with the higher medical care, once they step in, are in charge and owes any duty. We are all taught this issue in first aid classes, but courts have never identified it. Here the court uses the argument and supports it.

Too often we start any defense of a lawsuit by lining up the defenses. All too often in the outdoor recreation community, we need to see if (1) we did anything wrong and (2) is there a connection with what was done incorrectly or not done and the injury. That is, was a duty breached and was there a proximate connection between the breach and the injury.

Amazing how a well-argued decision can be so short.

What do you think? Leave a comment.

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Wilderness First Aid

Legally what is important about First Aid when you are away from EMS, what is not…………and what is just sleight of hand

Audience:                   Association of Outdoor Recreation and Education

Location:                    Keystone, Colorado

Date:                         2010

Presentation:                       Wilderness First Aid            http://rec-law.us/17L6pQB

clip_image002

This presentation looked at myths and realities of first aid and the special issues of wilderness first aid. It also examined the various state Good Samaritan statutes and why some first aid “designations” might now qualify under the act.

For additional articles on the subject see:

10 First Aid Myths                                                                                                    http://rec-law.us/ySaAwO

Another Way to Teach CPR                                                                                  http://rec-law.us/xEEaRo

CPR is not fool proof                                                                                               http://rec-law.us/w4PrpE

Everyone should write first aid protocols…. Or you could just buy a first aid book!http://rec-law.us/wguXEW

First Aid has its Limits. By law!                                                                              http://rec-law.us/xS1IEk

Letter to the Editor: Wilderness and Environmental Medicine                        http://rec-law.us/AjxzNj

Not a final decision, but I believe an indication of where the law of AED’s is heading however the basis for the decision is nuts!                                                                                          http://rec-law.us/yKC5te

Seriously, you have to send a memo about this, the issue is not what they are doing, it is who you are allowing to instruct.                                                                                                 http://rec-law.us/Ap1bRu

Stopping a rescue when someone is willing to perform may create liabilityhttp://rec-law.us/xuMtOt

Remember the law changes constantly, this presentation may be out of date. Check back at www.recreation-law.com and with your attorney to make sure the information is still valid.

What do you think? Leave a comment.

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By Recreation Law    Rec-law@recreation-law.com      James H. Moss         #Authorrank

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Not a final decision, but I believe an indication of where the law of AED’s is heading however the basis for the decision is nuts!

Miglino, Jr., etc., v Bally Total Fitness of Greater New York, Inc., et al., 2011 NY Slip Op 9603; 2011 N.Y. App. Div. LEXIS 9478

Calling 911 according to this court is starting a rescue which creates liability for failing to complete the rescue!

This case was appealed and upheld in Miglino, Jr., v Bally Total Fitness of Greater New York, Inc., 20 N.Y.3d 342; 985 N.E.2d 128; 961 N.Y.S.2d 364; 2013 N.Y. LEXIS 111; 2013 NY Slip Op 780.

There are a lot of motions, trial and appeals to go in this case before you could rely on this decision. However it is indicative of where the law is probably heading. If the statute requires you to have an AED (Automatic External Defibrillator) at your facility, you may be liable if you do not use it.

In this case, the deceased was playing racquet ball when he suffered a heart attack. An employee of the health club where he worked called 911 and went to his side with an AED. The employee left for an unknown reason and came back. When he left the deceased was still breathing. When he came back, a physician was attending the deceased.

At no time did the health club employee use the AED. The family of the deceased sued the health club. The allegations were that since the New York statute (General Business Law § 627-a) mandated the health club have an AED, then it was negligence not to use the AED. Whether or not the AED would have helped has seemed to have escaped the confines of the litigation.

The defendants moved to dismiss for failure to state a claim upon which relief can be granted. This means the allegations in the complaint of the plaintiff do not meet the minimum requirements to state a legal claim under the law and therefore the plaintiff’s case should be dismissed.

The legal basis of the motion was the statute did not require the use of the AED and any use of the AED was protected by the AED Good Samaritan Act, (Public Health Law § 3000-a). The motion of the defendants was denied and the defendants appealed that denial.

So? Summary of the case

First the appellate court looked at the statute requiring health clubs to have AEDs and employees trained in how to use the AED’s.

General Business Law § 627-a: automated external defibrillator requirements:

1. Every health club [with more than 500 members] shall have . . . at least one [AED], and shall have in attendance, at all times during staffed business hours, at least one individual performing employment . . . who holds a valid certification of completion of a course in the study of the operation of AEDs and a valid certification of the completion of a course in the training of cardiopulmonary resuscitation provided by a nationally recognized organization or association.

The court also looked at the AED Good Samaritan law.

“3. Pursuant to [Public Health Law §§ 3000-a and 3000-b], any public access defibrillation provider, or any employee . . . of the provider who, in accordance with . . . this section, voluntarily and without expectation of monetary compensation renders emergency medical or first aid treatment using an AED which has been made available pursuant to this section, to a person who is unconscious, ill or injured, shall be liable only pursuant to [Public Health Law § 3000-a].

The court stated the purpose of the statute was to save lives and therefore the health clubs were required to use the AEDs. “Stated differently, why statutorily mandate a health club facility to provide the device if there is no concomitant requirement to use it?”

A basic axiom in US law has always been there is no duty to rescue unless you placed the victim in the peril from which he needs rescued. By that, you can come across someone who is in need of help and you have no legal obligation to help.

Once you start to help though, you cannot leave the victim at that point. Once you start first aid, you cannot abandon the victim unless higher medical care arrives on the scene.

The court found the health club employee had started to rescue the deceased when he “directed that a 911 emergency call be made, sought medical assistance within the club, and took the decedent’s pulse.”

All three of the things the employee did were marginally, if at all, a rescue or first aid. If directing someone to call 911 constitutes starting a rescue, don’t expect me to pick up the phone if you are dying or tell someone else to call.

The court continues this stretch into the wild blue yonder with this statement. Since the health club employee was trained in the use of the AED, “his failure to use the device was tantamount to not acting carefully.”

Negligence can be proved for acting or in some cases for failing to act. However the failure to act had to have been predicated upon a duty to act that was more than speculation or hypothetical. Here the court has taken the fact that training now requires you to act on that training or you are liable. How far will this court go to hold someone liable for the bad luck in dying one day?

·        I am trained to provide first aid, yet I do not have the proper equipment, am I now liable when I cannot help the person so I do not help the person?

·        You are bleeding but I have no gloves or blood borne pathogen protection, even though I’ve been trained to stop your bleeding. Am I now liable for placing my family’s and my health above that of a stranger?

·        You are dying in the middle of a gun fight. I am safe and you are still surrounding by bullets, am I liable for not running out in the street to safe you when my training might assist you? Am I now required to risk my life because I have the training to save yours?

This seems like a stretch; however I don’t see these examples as any greater stretches than where the court has gone in this case.

The court found that because this was a preliminary motion that there may be enough information to keep the plaintiff’s claims alive, not matter how far this court had to stretch to do so.

So Now What?

The only thing this court has done for sure is scare people away from calling 911 when they see someone in trouble. Look at the liability of an elderly person with no physical ability and no training being held liable for the injuries of someone when all they did was call 911. They have no other skill set to assist someone in need, yet according to this court, calling 911 is the same as performing first aid.

My analysis, the standard of care on having and using AED’s is changing to one of if you have it by statute you must use it by law. First there are several issues that have not been discussed in this case that would eliminate any liability of the defendants.

1.       A physician is the senior medical person on the scene it is probably illegal for the health club employee to perform any medical care while the physician is in attendance.

2.      Would the AED have done anything?

3.      Is taking a pulse or calling for help rescue?

4.      If there was a pulse, does that not eliminate the need for the AED?

If this case continues on its present track, I think if you live in New York there are a few things you need to do.

1.       Go back to the legislature to define performing medical assistance to not include calling 911 or directing someone to call 911.

2.      Go back to the NY legislature and include in the Good Samaritan act that directing someone to get help does not create liability on your part from an injured third party.

And probably put an AED in your business, learn how to use it and use it.

What do you think? Leave a comment.

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This is how a standard in the industry changes

It moves up because the best get better.

Many people believe that the standards of an industry change three basic ways.

#985 Airport not in Japan

#985 Airport not in Japan (Photo credit: Nemo's great uncle)

1.)    The entire industry gets better.

2.)    The bottom, or worst part of the industry gets better; or

3.)    Written standards are created that makes the industry get better.

All three are incorrect. (The third belief serves the opposite effect and usually promotes lawsuits.)

Standards change when the best get better and move the standard in the industry upward. It was recently reported that the Boy Scouts of America purchased AED’s for all of its offices and camps. That is an example of the standard changing for camps. It may not affect the youth the camps are designed and run for, however it will affect the adults at the camp.

Has this changed the standard of care for adults and visitors at camps?

In this case we have the largest promoter of camping in the US with 4 million members and more than 300 offices and close to 400 camps putting AED’s in their camps. This is a major move on the part of the industry. A significant, as measured by numbers or percentages of the industry now has AED’s at their camps.

If other youth camps, either based on this, or on their own start installing AED’s as their camps the standard in the industry is shifting towards or requiring having AED’s in camps.

The standard changed.

What do you think? Leave a comment.

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History of the Boy Scouts of America

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