CJ-2026-00075 - Terry Moore v. ST. ANTHONY SHAWNEE HOSPITAL, INC., d/b/a SSM Health St. Anthony Hospital - Shawnee

What's This Case About?

Let’s be honest: most of us have had a medical appointment where we walked out more confused than when we walked in. But Terry Moore didn’t just walk out confused—she walked out of St. Anthony Shawnee Hospital with a ticking time bomb in her leg, and by the time she realized it, the damage was already done. According to her lawsuit, she was sent home after major knee surgery without any blood-thinning medication or proper preventive care, despite being at high risk for deep vein thrombosis—a condition that can lead to a deadly clot breaking loose and traveling to the lungs. And now, she’s suing the hospital, its parent corporations, and her orthopedic surgeon for $150,000, saying their negligence turned a routine procedure into a life-altering disaster. Welcome to the wild world of medical malpractice, where forgetting to prescribe an aspirin can allegedly cost you your mobility.

Terry Moore is a resident of Pottawatomie County, Oklahoma—just an everyday person trying to fix her chronic left knee pain. She wasn’t chasing miracles, just relief. Enter Dr. William John Hale II, an orthopedic surgeon who, according to the filing, presented himself as a competent and trustworthy doctor in the Shawnee community. He worked with SSM Health Bone & Joint, which operated under the umbrella of St. Anthony Shawnee Hospital, itself tied to larger corporate entities like SSM Health Care Corporation. In other words, this isn’t some back-alley clinic—it’s a full-fledged hospital system with multiple layers of administration, protocols, and, presumably, checklists. Terry trusted them enough to go under the knife for a total knee replacement on November 8, 2022. But what should’ve been the beginning of her recovery quickly spiraled into something far more serious.

Here’s where things go off the rails. According to Terry, her medical team never properly assessed her risk for developing blood clots—a standard precaution for any major surgery, especially joint replacements. Deep vein thrombosis (DVT) isn’t some rare fluke; it’s a well-known, preventable complication. And yet, she claims, no one flagged her as high risk. Worse, she says she was told to stop taking aspirin before surgery—which makes sense, since blood thinners can cause bleeding during operations—but then never told to start it back up afterward. That’s like defusing a bomb, walking away, and forgetting to rearm the security system. Within days, she developed a DVT in her left leg. That clot didn’t just cause pain—it led to permanent stiffness, restricted motion, and what she describes as “severe debilitation.” She missed the window for a follow-up procedure to manipulate her knee under anesthesia, which could’ve restored mobility. Now, she says, the damage is irreversible. All of this, she argues, traces back to a cascade of oversights that no competent medical team should have allowed.

So why is she in court? Because she believes this wasn’t just a mistake—it was negligence on multiple levels. Her lawsuit lays out a classic medical malpractice claim: doctors and hospitals have a duty to provide care that meets the accepted standard, and when they fail, and someone gets hurt, they can be held accountable. Terry’s saying that Dr. Hale and the hospital failed that duty in nearly every way possible. They didn’t assess her clot risk. They didn’t prescribe preventive meds. They didn’t monitor her post-op signs. They didn’t educate her on warning symptoms. And they didn’t act quickly when things went wrong. That’s not one error—that’s a system-wide breakdown. And under the legal doctrine of respondeat superior, the hospital can be held liable for the actions (or inactions) of its employees and contractors, meaning the corporate entities aren’t off the hook just because the doctor was the one holding the scalpel.

But here’s where it gets spicy: Terry isn’t just asking for compensation. She’s demanding punitive damages—$75,000 of them, on top of the $75,000 she wants for her actual losses. And punitive damages? Those aren’t about making the victim whole. They’re about punishment. They’re the legal system’s way of saying, “What you did was so reckless, so beyond the pale, that we need to slap you hard enough to make others think twice.” To win punitive damages, you usually have to show something worse than mere negligence—think intentional harm, gross recklessness, or a total disregard for patient safety. Terry’s alleging exactly that: that these defendants knew the risks, ignored them, and sent her home like everything was fine, even though their own actions created a dangerous situation. That’s not just bad medicine—it’s the kind of thing that gives hospitals nightmares during malpractice depositions.

Now, let’s talk about the money. $150,000 might sound like a lot, especially if you’re picturing a small-town lawsuit over a sore knee. But when you break it down, it starts to make sense. She’s claiming permanent physical impairment, ongoing pain, future medical costs, and emotional distress—all things that can add up fast. And while $75,000 in actual damages might not cover a lifetime of therapy and specialists, it’s a starting point. The real eyebrow-raiser is the equal demand for punitive damages. That’s a bold move, especially for a pro se plaintiff—that’s legal jargon for someone representing themselves, which Terry is. No lawyer. No legal team. Just her, her story, and a whole lot of courage. That alone makes this case compelling. She’s not just fighting for money; she’s fighting to be heard, to hold a powerful medical system accountable with nothing but her own voice.

Our take? The most absurd part isn’t that someone got a blood clot after surgery—that happens. It’s that none of the standard safeguards seem to have kicked in. In 2022. In a hospital that’s part of a major health network. We’re talking about a preventable complication that medical guidelines have been addressing for decades. And yet, Terry Moore was sent home with zero DVT prophylaxis, no instructions, no follow-up plan—just a fresh surgical wound and a prayer. If the allegations are true, this isn’t just negligence. It’s institutional complacency. And while we’re not rooting for anyone to get rich off a lawsuit, we are rooting for accountability. Someone should’ve caught this. Someone had to. The fact that Terry had to file this petition herself, in longhand prose with all the legal citations she could muster, only adds to the tragedy. This shouldn’t have happened. And if the system works—even a little—maybe, just maybe, it won’t happen to someone else. Because in the grand soap opera of civil court, the real victory isn’t the verdict. It’s the warning.

Case Overview

$150,000 Demand Jury Trial Petition

Jurisdiction

District Court, OKLAHOMA

Relief Sought

$75,000 Monetary

$75,000 Punitive

Plaintiffs

Terry Moore individual
Rep: Pro Se

Defendants

ST. ANTHONY SHAWNEE HOSPITAL, INC., d/b/a SSM Health St. Anthony Hospital - Shawnee business
SSM HEALTH CARE CORPORATION business
SSM HEALTH CARE OF OKLAHOMA, INC., d/b/a St. Anthony Shawnee Physicians d/b/a SSM Health Bone & Joint business
William John Hale II, M.D. individual

Claims

#	Cause of Action	Description
1	Negligence	Defendants' negligence caused plaintiff's deep venous thrombosis.
2	Punitive Damages	Defendants' intentional and reckless conduct warrants punitive damages.

Petition Text

1,325 words

IN THE DISTRICT COURT IN AND FOR POTTAWATOMIE COUNTY STATE OF OKLAHOMA TERRY MOORE, an Individual, Plaintiff, v. ST. ANTHONY SHAWNEE HOSPITAL, INC., d/b/a SSM Health St. Anthony Hospital – Shawnee, a Domestic Corporation; SSM HEALTH CARE CORPORATION, a Foreign Corporation; SSM HEALTH CARE OF OKLAHOMA, INC., d/b/a St. Anthony Shawnee Physicians d/b/a SSM Health Bone & Joint, a Domestic Corporation; and WILLIAM JOHN HALE II, M.D., an Individual, Defendants. PETITION COME NOW the Plaintiff, Terry Moore, and for her causes of action against the Defendants, submits and sets forth as follows: PARTIES, JURISDICTION AND VENUE 1. Plaintiff Terry Moore is and was at all relevant times hereto a resident of Pottawatomie County, Oklahoma. 2. St. Anthony Shawnee Hospital, Inc., d/b/a SSM Health St. Anthony Hospital - Shawnee ("SAH Shawnee"); a Domestic Corporation, is organized under the laws of the State of Oklahoma, with its principal place of business located in Pottawatomie County, Oklahoma. 3. Defendant SSM Health Care Corporation ("SSM"), a Foreign Corporation, is registered with the State of Oklahoma and has significant ties to Pottawatomie County, Oklahoma. 4. Defendant SSM Health Care of Oklahoma, Inc., d/b/a St. Anthony Shawnee Physicians d/b/a SSM Health Bone & Joint ("Bone & Joint"), a Domestic Corporation, is organized under the laws of the State of Oklahoma, with significant ties to Pottawatomie County, Oklahoma. 5. Upon information and belief, Defendant SSM and Bone & Joint have multiple locations, including but not limited to 3315 Kethley Road in Shawnee, Oklahoma. 6. Defendant William John Hale II, M.D. ("Hale") was, at all relevant times hereto, licensed to practice medicine in the State of Oklahoma. Defendant Hale held himself out to the community as a competent orthopedic physician and surgeon in the State of Oklahoma. 7. Upon information and belief, Defendant Hale was at all times relevant hereto, an agent, employee, contractor, and/or servant of Defendant SAH Shawnee, SSM, and/or Bone & Joint. 8. The events and actions giving rise to this cause of action occurred in Pottawatomie County, Oklahoma. 9. This Court has jurisdiction, and the venue is proper in Pottawatomie County, Oklahoma. STATEMENT OF FACTS 10. Paragraphs 1-9 are incorporated herein by reference. 11. Ms. Moore saw Defendant Hale on several occasions beginning on or before November 5, 2021, for left knee pain. 12. Agents of Defendant Bone & Joint, including but not limited to Defendant Hale, recommended total knee replacement surgery. 13. At the direction of Defendants, including but not limited to Defendants Bone & Joint and Hale, Ms. Moore presented to Defendant SAH Shawnee on or about November 8, 2022. 14. Defendants, including but not limited to Defendant Hale, failed to risk stratify Ms. Moore as high risk for developing deep venous thromboses. 15. Ms. Moore's elevated risk was recklessly ignored, and she was sent home after surgery on or about November 10, 2022, without DVT prophylactic recommendations or treatment. 16. In fact, Ms. Moore was instructed to stop taking her aspirin prior to the November 8 surgery and was never told to resume this, or any other, blood thinning medications for DVT prophylaxis. 17. Following the November 8, 2022, surgery, Ms. Moore developed a deep venous thrombosis in her left leg due to either a failure to implement and adhere to adequate mechanical DVT prophylactic protocols, and/or a failure to ensure pharmacologic DVT prophylaxis with anticoagulation or take other necessary, preventative measures. 18. As a result of Defendants' negligence and the negligence of their employees and/or agents, Ms. Moore has suffered multiple injuries including, but not limited to, permanent deformity, permanent impairment, past and future medical expenses, past and future mental and physical pain and suffering, loss of consortium, and other actual damages in excess of Seventy-Five Thousand Dollars ($75,000.00). CAUSES OF ACTION COUNT I. NEGLIGENCE 19. Paragraphs 1 through 18 are incorporated herein by reference. 20. Defendants, as well as Defendants' employees, agents, and/or contractors, owed a duty to Ms. Moore to provide reasonable medical care and treatment, including proper informed consent and a duty to use their best judgment and apply, with ordinary care and diligence, the knowledge, and skill possessed by other similarly situated individuals in the industry. 21. Defendants knew or reasonably should have known that the procedure performed on Ms. Moore on November 8, 2022, carried significant risk of deep venous thrombosis. 22. Upon information and belief that will be confirmed in discovery, Defendants – individually and collectively – failed to conform to the applicable standard of care in the treatment of Ms. Moore and were negligent in many ways including, but not limited to, the following: a. failing to timely recognize signs, symptoms, and findings that were consistent with deep venous thrombosis which they caused, b. failing to appreciate signs and symptoms of acute deep venous thrombosis which they knew, or reasonably should have known, required emergent workup and intervention, c. failing to advise Ms. Moore of appropriate action to take and how soon, d. failing to timely act in diagnosing and treating Ms. Moore’s deep venous thrombosis, which they knew, or reasonably should have known, required emergent workup, identification, and intervention, e. failing to timely refer Ms. Moore to the appropriate consultants who could render medical care and treatment for her deep venous thrombosis, and f. failure to respond appropriately to Moore’s medical condition when they knew or reasonably should have known that their acts and omissions had exposed her to severe injury and continued pain and suffering as a direct result of the course and method of treatment they provided. 23. Defendants, by and through their agents and/or employees, failed to inform Ms. Moore of the material risks involved in her course of treatment; that Defendants, by and through their agents and/or employees, failed to inform Ms. Moore of alternative treatments and the reasonably foreseeable material risks of each alternative; and that Ms. Moore would have chosen the option of a different course of treatment had the alternative and material risks of each been made known. 24. The breach of this duty by Defendants and their employees/agents/contractors is the actual and proximate cause of Ms. Moore' injuries. 25. As an actual and proximate cause of the negligence of Defendants, their agents, and staff, Ms. Moore endured physical and mental pain and suffering. 26. As an actual and proximate cause of the negligence of Defendants, their agents, and staff, Ms. Moore developed significant motion restriction in her left knee and leg. 27. As an actual and proximate cause of the negligence of Defendants, their agents, and staff, Ms. Moore was unable to undergo manipulation of her left knee under anesthesia in a timely manner and now has permanent stiffness in her left knee and severe debilitation. 28. Defendants are vicariously liable for the negligence of their employees and agents pursuant to the legal doctrines of respondeat superior and/or ostensible agency. 29. As a result of Defendants’ combined negligence, Ms. Moore has suffered multiple injuries including, but not limited to, permanent deformity, permanent impairment, past and future medical expenses, past and future mental and physical pain and suffering, loss of consortium, and other actual damages in excess of Seventy-Five Thousand Dollars ($75,000.00). Count II. Punitive Damages 30. Paragraphs 1-29 above are incorporated herein by reference. 31. Defendants’ intentional, wanton and reckless conduct in disregard of Ms. Moore and others similarly situated were conducted with full knowledge that Defendant knew or should have known, of the severe adverse consequences of their actions. 32. Defendants’ actions constituted reckless disregard for the health and safety of Ms. Moore. 33. The acts of Defendant(s) were wrongful, culpable, and so egregious that punitive damages in a sum that exceeds $75,000.00 should be awarded against Defendant(s) to set an example to others similarly situated that such inexcusable conduct will not be tolerated in our community. WHEREFORE, based on the foregoing, Ms. Moore prays that this Court grants her the relief sought, including but not limited to actual damages in excess of Seventy-Five Thousand Dollars ($75,000.00), punitive damages in excess of Seventy-Five Thousand Dollars ($75,000.00), costs, attorney fees and such other relief as the Court deems just and equitable. Respectfully submitted, Terry Moore TERRY MOORE, PRO SE PLAINTIFF 2524 NORTH HARRISON, TRAILER 11