What questions should be asked of a defendant surgeon in a deposition who injured the phrenic nerve during a mitral valve replacement redo?

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Last updated: June 9, 2025View editorial policy

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From the Guidelines

When deposing a defendant surgeon who injured the phrenic nerve during a redo mitral valve replacement, the primary focus should be on establishing the standard of care and potential negligence, with specific emphasis on preoperative planning, intraoperative techniques, and postoperative management, as highlighted in studies on minimally invasive mitral valve surgery 1. To effectively question the defendant surgeon, consider the following key areas:

  • Experience and training: Ask about the surgeon's experience with redo cardiac procedures and specific training in managing anatomical variations near the phrenic nerve, considering that phrenic nerve injury is more common in redo operations 1.
  • Preoperative planning: Inquire about the review of prior surgical records and imaging studies to identify potential adhesions or anatomical distortions from the previous surgery, which could increase the risk of phrenic nerve injury.
  • Surgical approach: Question the specific surgical approach used, whether alternative approaches were considered, and what precautions were taken to identify and protect the phrenic nerve during dissection, given that direct, traction, or thermal injuries can occur 1.
  • Intraoperative nerve monitoring: Ask about the use of intraoperative nerve monitoring, if employed, to assess the surgeon's efforts to minimize the risk of nerve injury.
  • Recognition and response to injury: Determine the moment when the nerve injury was recognized, what immediate actions were taken, and whether appropriate consultation was sought, as many patients can recover within 3 to 6 months if the nerve is not transected 1.
  • Informed consent: Question the surgeon about the informed consent process, specifically whether phrenic nerve injury was disclosed as a potential complication, to assess the patient's awareness of the risks involved.
  • Postoperative management: Explore the diagnostic measures taken to confirm the injury, treatments offered, and follow-up care provided, to evaluate the surgeon's response to the complication and its impact on the patient's quality of life.

From the Research

Questions to Ask the Defendant Surgeon

To effectively depose a defendant surgeon who injured the phrenic nerve during a mitral valve replacement redo, several key questions should be asked, including:

  • What was the surgical approach used during the mitral valve replacement redo, and how might this have contributed to the phrenic nerve injury? 2
  • Can the defendant describe the specific techniques used for myocardial protection and internal mammary artery harvesting, as these have been associated with phrenic nerve injury in the past? 2
  • How did the defendant assess and monitor the patient's phrenic nerve function during and after the surgery, and were any precautions taken to avoid injury?
  • What treatment strategies were considered or implemented for the patient's phrenic nerve injury, such as early tracheostomy or diaphragmatic plication, and what was the rationale behind these decisions? 2
  • Were any antibiotics or neuromuscular blocking agents used during the surgery that could have potentially interacted with each other or with the patient's phrenic nerve function, and if so, how were their effects monitored and managed? 3

Understanding the Context of Phrenic Nerve Injury

Phrenic nerve injury following cardiac surgery, including mitral valve replacement, is a recognized complication that can result from various factors, including cold-induced injury during myocardial protection and mechanical injury during surgical procedures 2. The consequences of such an injury can vary widely, from asymptomatic radiographic abnormalities to severe pulmonary dysfunction requiring prolonged mechanical ventilation 2.

Deposition Strategy

A well-prepared deposition is crucial in a medical malpractice suit, and the defendant should be prepared to address questions about their actions and decisions before, during, and after the surgery 4. The goal is to understand the events leading to the phrenic nerve injury and the subsequent management of the patient's condition, which can inform the legal proceedings and potential outcomes.

References

Guideline

Guideline Directed Topic Overview

Dr.Oracle Medical Advisory Board & Editors, 2025

Research

Phrenic nerve injury following cardiac surgery: a review.

Journal of cardiac surgery, 1998

Research

The deposition. The defendant's perspective.

Clinics in plastic surgery, 1999

Professional Medical Disclaimer

This information is intended for healthcare professionals. Any medical decision-making should rely on clinical judgment and independently verified information. The content provided herein does not replace professional discretion and should be considered supplementary to established clinical guidelines. Healthcare providers should verify all information against primary literature and current practice standards before application in patient care. Dr.Oracle assumes no liability for clinical decisions based on this content.

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