Catherine and Ross Kesterson, individually, and their minor daughter, Kyla, by and through her parents, appeal from a jury verdict and final judgment in favor of the defendants in this medical malpractice case. Following a bifurcated trial on the issue of liability, the jury returned a verdict in favor of Walter Jarrett, M.D., Athens Obstetrics and Gynecology, P.C., and St. Mary’s Healthcare System, Inc. d/b/a St. Mary’s Hospital. On appeal, the Kestersons contend the State Court of Clarke County erred in granting the defendants’ request to limit Kyla’s presence in the courtroom during the liability phase of the trial, in limiting their cross-examination of Jarrett, and in excluding video evidence offered to illustrate Kyla’s injuries. For the reasons that follow, we find no reversible error and affirm the jury’s verdict. Viewed in the light most favorable to the jury’s verdict,1 the record shows the following facts relevant to this appeal. At about 6:15 a.m. on October 20, 1998, Catherine Kesterson “Kesterson” was admitted to St. Mary’s Hospital so that her obstetrician, Jarrett, could induce labor. Jarrett administered Pitocin, a medication used to stimulate uterine contractions. The hospital nursing staff connected Kesterson to a fetal heart rate monitor, an external device which generated printed information documenting any changes in the fetus’ heart rate. The nurses monitored Kesterson’s labor until she delivered Kyla at 8:15 p.m. Jarrett examined Kesterson at 2:30 p.m., 4:00 p.m., and 5:45 p.m. During the last examination, Jarrett noted that Kesterson was in active labor, but that her cervix was not sufficiently dilated to deliver. Jarrett ordered an epidural for Kesterson and then went to a meeting, leaving his patient in the care of his partner, Dr. Van Herrin.
The day nurse, who was present until 7:00 p.m., did not observe anything about Kesterson’s labor, including any changes in the fetus’ heart rate, that caused her concern. Although she noted “variable decelerations” of the fetus’ heart rate, those were either associated with Kesterson’s contractions or related to the fact that she was sitting up for an epidural, and the nurse did not consider them to be unusual. When the evening nurse came on duty at 7:00 p.m., she reviewed the fetal heart rate monitor and noted: “Fetal heart rate with minimal variability; occasional variable decel, some late occurring; patient turned to full right lateral position.” Nothing she observed caused her to be concerned. Around 7:34 p.m., the evening nurse observed that the heart rate monitor had registered a more significant deceleration of the fetus’ heart rate and that it was not returning to normal as quickly as it had before, suggesting a deceleration unrelated to contractions. After giving Kesterson oxygen, the nurse paged Herrin and relayed her observations. Herrin responded within minutes, examined Kesterson, and ordered an emergency Caesarean section. Shortly thereafter, he delivered Kyla.
