Rx & The Law

Lack of Pharmacy Management Can Be Expensive

by Donald McGuire, R.Ph., J.D.
Professional Claims Attorney
Pharmacists Mutual Insurance Company

A recent court decision, Hundley v. Rite Aid[1], provides two lessons for pharmacists and their employers.  Seven-year-old Gabrielle Hundley was diagnosed with Attention Deficit Hyperactivity Disorder and was prescribed Ritalin.  The prescription was accidentally filled with Glynase 6mg instead of Ritalin.  After 2 doses of Glynase, the child lost consciousness and was transported to the hospital in a hypoglycemic coma.  The child’s physicians discovered the cause of the hypoglycemia, but not before she suffered permanent brain damage.  The parents filed suit on behalf of their daughter on March 23, 1995.

While there are a number of complex legal issues involving experts, evidence, procedure, and damages in this case, this article will focus on the lessons to be learned from the pharmacy issues of the case.  The first lesson is how not to handle a dispensing error.  An article in Pharmacists Mutual’s Risk Management in Pharmacy newsletter advises pharmacists to own up to obvious mistakes:  “Above all, be honest.  Patients will usually forgive a human error, but not a cover-up.” [2]  

The Hundleys served interrogatories and requests for production of documents on July 14, 1995.  The interrogatories went unanswered.  Three and a half months later, the Hundleys filed a motion to compel Rite Aid to respond.  Rite Aid agreed to respond prior to the court’s order to do so, but failed to follow through with that promise.  Partial answers were finally delivered in January and February of 1996.  Two further requests for information were presented to Rite Aid and went unanswered.  The court ordered full compliance with all requests by May 15, 1996 or a default judgment would be entered against Rite Aid. 

When the answer was finally given, Rite Aid stated that the computer data and other records required by law could not be located and that the pharmacy had not dispensed any Glynase 6mg during the 3 month period surrounding this incident.  In July 1996, the court again ordered Rite Aid to produce this information by August 16, 1996 or again face a default judgment.  The missing computer records were finally located and they indicated that Glynase had in fact been dispensed by this pharmacy during the time in question and for the same quantity and strength that had been received by Mrs. Hundley.  The prescriptions themselves were also produced although the Ritalin prescription and the Glynase prescription were still missing.  The court had this to say about the records produced:

Now, over a period of more than a year since this case was filed, documents and materials which have been exclusively in the possession, custody and control of Defendant are surfacing which appear to make it highly likely that the claimed mis-fill did occur and give some indication as to how it occurred.  Rather than come forward with all such information and evidence in the ordinary course of discovery, Defendant took the path of concealment and obstructed Plaintiffs’ attempts to ascertain the truth.[3] 

For its conduct from March 1995 through August 1996, the court charged Rite Aid with over $40,000 in fines, attorney fees and costs for discovery abuses.

The second lesson of this case is for pharmacy managers.  Management needs to take a more active role in overseeing the quality of its professional activities to ensure that the safety of the pharmacy’s patients is being adequately protected.  At the eventual trial, evidence was presented that Rite Aid had no policies or procedures designed to ensure the competence of its pharmacists.  Also, Rite Aid had no policies or procedures regarding the filling and labeling of prescriptions or the storage and handling of drugs in the pharmacy.  All of these issues were left to the judgment of the pharmacists working at that store.  The pharmacy had no system in place for risk management or for quality assurance. 

The jury awarded Gabrielle $5 million in actual damages and $10 million in punitive damages.  The jury also awarded her parents $20,000 in actual damages and $1 million in punitive damages.  Punitive damages are awarded in a trial to punish a defendant for willful or wanton misconduct.  Because of the evidence presented at trial regarding the lack of policies and procedures, the appellate court allowed the punitive damages to stand.

[1] Hundley v. Rite Aid of So. Car., Inc., 2000 WL 225531 (SC App., Feb. 28, 2000)
[2] Volume 7, Number 2, Winter 1998-1999
[3] Hundley at page *9.