NEW ORLEANS - The Fifth Circuit U.S. Court of Appeals on Nov. 13 reversed summary judgment for the defendant in a medical malpractice action brought by the family of a man who bled to death while in the hospital, concluding that evidence showed that the man was "an elderly, weak patient with a high risk for falls and susceptibility to bleeding, was sedated yet given a laxative that could make him have to get out of bed in a hurry" (Maurice Smith, et al. v. Christus St. Michaels Health System, No. 12-40057, 5th Cir.; 2012 U.S. App. LEXIS 23317).