Background
Anna Marie Turner was induced into labor on December 5, 2016, due to pregnancy complications. During labor on December 6, the fetal heart rate monitor showed variable recelerations, indicating possible oxygen deprivation. When Dr. Charles Brent Boles arrived, he found the baby in an occiput posterior position (face-up rather than the preferred face-down orientation), which complicates vaginal delivery. After approximately twenty minutes of pushing without progress and persistent concerning fetal heart rate patterns, Dr. Boles attempted a manual rotation to turn the baby’s head to the preferred position.
Despite the attempted rotation, Dr. Boles was unable to reposition the baby and proceeded with a cesarean section. The delivery proved difficult, requiring force to dislodge the baby from the mother’s pelvis. The newborn, Kristyn Elise Turner, was born on December 6, 2016, but was found to have multiple skull fractures with associated hemorrhages. She died four days later from traumatic brain injuries. The autopsy identified birth trauma as the underlying cause of death.
The parents sued Dr. Boles for negligent obstetric care, alleging that the manual rotation caused the skull fractures. At trial, a jury found in favor of Dr. Boles, determining he did not deviate from the standard of care. The parents appealed, raising five issues including evidentiary rulings, jury instructions, and alleged counsel misconduct.
The Court’s Holding
The Tennessee Court of Appeals affirmed the judgment for Dr. Boles in all respects. The central issue at trial was whether Dr. Boles deviated from the standard of care in performing the manual rotation attempt. The jury, presented with conflicting expert testimony, resolved the disputed facts in the defendant’s favor. The plaintiffs’ experts (an obstetrician and pediatric pathologist) testified that manual rotation was unnecessary and that excessive force caused the fractures. The defense experts (an obstetrician and neuroradiologist), along with Dr. Boles himself—who had performed approximately 1,000 manual rotations over his career without incident—testified that the maneuver was a standard, safe intervention warranted by the clinical circumstances and that the injuries likely resulted from other forces such as cephalopelvic disproportion or the difficult cesarean extraction.
The appellate court found that the jury’s verdict turned solely on whether Dr. Boles met the standard of care, and because the jury found he did, causation was never reached. Thus, the court held that even if trial errors occurred in limiting the plaintiffs’ causation expert’s testimony or excluding his exhibits, such errors were harmless and did not affect the judgment. Additionally, the trial court properly excluded evidence of Dr. Boles’s 2023 medical license suspension—which involved a record-keeping violation occurring four years after the delivery—under the rule excluding evidence whose probative value is substantially outweighed by unfair prejudice.
The court rejected the misconduct claims, finding that defense counsel’s closing arguments about the autopsy report, though challengeable, did not rise to actionable misconduct and were corrected by plaintiffs’ counsel’s rebuttal argument. Since the jury never reached causation, any potential misstatements about the cause of death could not have affected the verdict.
Key Takeaways
- A manual rotation during complicated delivery remains within the standard of obstetric care when performed in response to a non-reassuring fetal heart rate and failure to progress, even absent support in medical literature for this specific causation theory.
- When a jury verdict turns on standard-of-care liability and the jury finds no deviation, appellate courts need not address harmless errors in causation-related evidence, and harmless error review bars reversal.
- A physician’s license suspension for post-dispute regulatory violations can be excluded as unduly prejudicial, particularly when the violation is unrelated to patient care and does not directly contradict trial testimony about the challenged treatment.
- Plaintiff experts’ opinions unsubstantiated by medical literature, though admissible, do not guarantee recovery when defense experts and the defendant physician offer contrary opinions grounded in clinical experience and standard protocols.
Why It Matters
This decision affirms the importance of clinical judgment and experience in obstetric malpractice cases. The court’s affirmance of a jury verdict for the defendant, despite expert testimony from plaintiffs claiming unnecessary intervention and excessive force, shows that physicians performing standard interventions in response to objective clinical findings—even when the outcome is tragic—may succeed in defending against liability. The decision also confirms that disagreement among equally qualified experts about causation is a jury question, and juries may credit a defendant physician’s years of experience over expert opinion offered without supporting medical literature.
The ruling also clarifies evidentiary boundaries in medical malpractice litigation, establishing that a defendant’s unrelated regulatory disciplinary history is excludable as unfairly prejudicial and that appellate review of evidentiary errors is limited by the harmless error doctrine when the jury’s verdict rests on an independent basis. This combination restricts the tools available to plaintiffs in pursuing obstetric malpractice claims and reflects judicial caution about allowing collateral matters to distract juries from the core question: whether the defendant physician deviated from the applicable standard of care.