Court Rules Baltimore County EMS Not Liable for Patient’s Death

The Maryland Court of Special Appeals has upheld a lower court ruling that neither Baltimore County nor an EMS crew could be held liable for the death of a patient in 2015. Baltimore County Fire Department Paramedic Nicole Nappi and EMT Traci Jackson were sued by the family of Ceontay Coit, who died on December 11, 2015.

Coit’s family claimed the EMS crew was slow in arriving on scene, were “lackadaisical” when they arrived, administered Narcan to a non-opioid patient, and provided “no useful aid” to the patient. The court disagreed, concluding the plaintiffs were “trying to generate evidence of willful conduct or gross negligence” by taking information out of context in order to circumvent the immunity protection the emergency responders otherwise would have. Quoting from the decision:

  • There is insufficient evidence to support [the Coit family’s] claim that Paramedic Nappi’s and EMT Jackson’s pre-arrival conduct was willful or grossly negligent.
  • There is also insufficient evidence that Paramedic Nappi’s and EMT Jackson’s postarrival conduct was willful or grossly negligent.
  • Although the Court recognizes that seconds may seem like minutes during an emergency, the evidence demonstrates that, upon entering the basement of Mr. Watkins’ home, Paramedic Nappi and EMT Jackson promptly assessed and treated Mr. Coit.
  • They checked for a pulse, observed agonal respirations, placed an oxygen mask on Mr. Coit, prepared an intravenous line and began administering fluids, began transcutaneous cardiac pacing to address Mr. Coit’s heart rate, administered Narcan, and administered Atropine.
  • Treatment and assessment of Mr. Coit’s condition continued after Mr. Coit was removed from the house and taken to the medic unit for transport to Northwest Hospital.
  • He was intubated with an endotracheal intubation tube.
  • Emergency medical service providers began administering CPR and administered Epinephrine during transport to Northwest Hospital.
  • Upon arrival at Northwest Hospital, Paramedic Nappi reported to emergency department personnel regarding what treatment had been provided and the status of Mr. Coit’s condition.
  • Even if Paramedic Nappi and EMT Jackson were, in some way, negligent in their assessment and treatment of Mr. Coit, which the Court is not suggesting, there is not sufficient evidence of gross negligence regarding their postarrival conduct.

The court concluded that Nappi, Jackson and Baltimore County had immunity protection, and that summary judgment in their favor was warranted on the facts.

  • Everyone, of course, wishes that there was a different outcome that resulted in Mr. Coit being alive today. It is tragic and unfortunate that he is not.
  • This Court is required to evaluate the evidentiary record within the framework of the applicable law to determine if there is sufficient evidence to support [appellants’] claims.
  • Based on the undisputed facts in the evidentiary record, Paramedic Nappi, EMT Jackson and Baltimore County are entitled to judgment as a matter of law.
  • Paramedic Nappi and EMT Jackson are entitled to statutory immunity based on the Good Samaritan Act and the Fire & Rescue Companies Act because their conduct was neither willful nor grossly negligent.
  • Baltimore County is entitled to governmental immunity under the [Local Government Tort Claims Act] because there is no basis for any direct claims against it.
  • Even if the parties were not entitled to immunity, there is insufficient evidence to satisfy the causation requirement.

Here is a copy of the decision:

About Curt Varone

Curt Varone has over 40 years of fire service experience and 30 as a practicing attorney licensed in both Rhode Island and Maine. His background includes 29 years as a career firefighter in Providence (retiring as a Deputy Assistant Chief), as well as volunteer and paid on call experience. He is the author of two books: Legal Considerations for Fire and Emergency Services, (2006, 2nd ed. 2011, 3rd ed. 2014) and Fire Officer's Legal Handbook (2007), and is a contributing editor for Firehouse Magazine writing the Fire Law column.
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