Lucas: establishing the standard of care

Facts and context

Peter Lucas consulted ophthalmologist Dr. Prospero Tuaño for conjunctivitis and later epidemic keratoconjunctivitis. Over several visits, Dr. Tuaño prescribed and adjusted steroid-containing eye drops, including Maxitrol and Blephamide. Peter reported recurrent symptoms, pain, headache, and blurred vision. When his intraocular pressure was eventually measured at a markedly elevated level, the steroid was stopped and treatment for glaucoma was begun. Peter later underwent further ophthalmic treatment but sustained lasting visual impairment.

Peter and his family alleged that prolonged steroid use without adequate pressure monitoring caused steroid-induced glaucoma. Dr. Tuaño maintained that he had examined Peter repeatedly, tapered or changed medication as the condition evolved, and responded once elevated pressure was detected. The parties presented competing medical testimony about accepted ophthalmic practice, Peter’s susceptibility as a steroid responder, and causation.

Issue

Did competent expert evidence establish the standard for prescribing and monitoring the steroid eye drops, a departure by Dr. Tuaño, and a probable causal connection between that departure and Peter’s visual injury?

Ruling and doctrine

The Court upheld dismissal of the claim. Medical negligence required proof of duty, breach, injury, and proximate causation. Although Dr. Tuaño’s acceptance of Peter created a professional duty, the plaintiffs’ evidence did not establish that his treatment and monitoring fell below the standard of a reasonably competent ophthalmologist or that an identified breach probably caused the injury.

The Court would not infer the technical standard or causal mechanism from the injury alone. The result was a failure of proof on the record, not a general endorsement of prolonged steroid use without patient-specific monitoring.

Practice implications

Parao Law practice guidance

For physicians

• Record the clinical problem, findings, working diagnosis, and reason for choosing the treatment.
• Explain material treatment risks and the follow-up needed to assess response or complications. Make the patient’s next step understandable.
• When prescribing, record the patient-specific rationale and monitoring plan where relevant; reassess when new information changes the risk-benefit judgment.
• If the problem exceeds your competence, obtain appropriate consultation or referral and document the transfer of information.

For lawyers

• Organize proof under duty, breach, injury, and proximate causation. Identify the evidence supporting each element and the gaps.
• Brief a relevant expert with the complete treatment chronology. Ask what a reasonably competent physician would have done in comparable circumstances and precisely how the defendant departed from it.
• Ask the expert to explain the causal mechanism and competing causes, not merely give a conclusion of malpractice.
• Do not treat injury alone as proof of breach or a doctor’s credentials alone as proof of adequate care.

Limits of the ruling

Dismissal for failure of proof is not a judicial endorsement of every possible use of a medication or treatment. The decision concerns the claim and evidence presented. Its framework should be applied to comparable circumstances, not used to impose hindsight or a guarantee of cure.