Justia Civil Procedure Opinion Summaries

Joel Phillip McNinch, Jr., a dementia patient with other serious health issues, was admitted to Brandon Nursing and Rehabilitation Center, LLC in June 2019. He was later admitted to Merit Health Rankin due to combative behaviors related to his dementia. He developed a decubitus ulcer and was admitted to St. Dominic Hospital, where he died the next day. His widow, Cheryl McNinch, requested her husband's medical records from Brandon Nursing and Merit Health soon after his death and received them in mid-December 2019. She filed a complaint in January 2022, alleging negligence, medical malpractice, gross negligence, and reckless disregard, claiming that substandard care had accelerated her husband's health deterioration and led to his death.The defendants moved to dismiss the case, arguing that the action was barred by the two-year statute of limitations. Mrs. McNinch argued that the discovery rule operated to toll the statute of limitations until she received the medical records. The trial court converted the defendant’s motion to dismiss into a motion for summary judgment and granted the motion without holding a hearing.The Supreme Court of Mississippi reversed the trial court's decision, finding that the trial court erred by granting summary judgment to the defendants. The Supreme Court held that there were genuine issues of material fact regarding whether Mrs. McNinch had knowledge of negligent conduct through personal observation or other means prior to or at the time of Mr. McNinch’s death. The court found that the discovery rule could operate to toll the statute of limitations when the medical records are necessary to discover the negligence. The court concluded that Mrs. McNinch exercised reasonable diligence in requesting the medical records promptly, and therefore, the complaint was filed within the statute of limitations. The case was remanded to the circuit court for further proceedings. View "McNINCH v. BRANDON NURSING & REHABILITATION CENTER" on Justia Law

The case involves a dispute over the eligibility of a married individual, Costa Tingos, for Medicaid long-term care benefits. Costa and his wife, Mary, had been married for over 50 years, but had kept their finances largely separate due to Costa's history of gambling and financial mismanagement. When Costa moved into a nursing home, he applied for Medicaid benefits. However, Mary refused to provide information about her income and assets, which was necessary to determine Costa's eligibility. Costa argued that Mary's refusal to cooperate should not affect his eligibility.The case was initially heard by the Massachusetts Medicaid program, MassHealth, which denied Costa's application. Costa appealed to the MassHealth board of hearings, which also denied his appeal. Costa then sought judicial review in the Superior Court, which vacated the board's decision and remanded the case back to the board. After two more rounds of hearings and appeals, the Superior Court affirmed the board's decision to deny Costa's application.The Supreme Judicial Court of Massachusetts affirmed the decision of the Superior Court. The court held that the board's interpretation of the phrase "refuses to cooperate" in the relevant regulation was reasonable. The court found that Mary's refusal to disclose her financial information did not constitute a refusal to cooperate within the meaning of the regulation, given the couple's long history of cooperation in other aspects of their marriage. The court also rejected Costa's argument that the board's decision was arbitrary and capricious. View "Freiner v. Secretary of the Executive Office of Health and Human Services" on Justia Law

The case revolves around Tokvan Ly, a man suffering from severe mental illness, who was incarcerated in the Scott County Jail. The district court found Ly incompetent to face criminal proceedings and ordered him committed to the care of the appellant, Jodi Harpstead, the Commissioner of Human Services. The law requires that persons in Ly's position be prioritized for admission to state-operated treatment programs and be admitted within 48 hours. However, Ly was not admitted within this timeframe. Fifteen days after his commitment, Ly remained in jail and was not receiving the specialized treatment needed for his severe mental illness. Consequently, he filed a petition for writs of mandamus and habeas corpus, alleging that the Commissioner was failing to comply with a mandatory duty to admit him to treatment within 48 hours under the Priority Admission statute and seeking damages resulting from his delayed admission to treatment.The district court issued a peremptory writ of mandamus that determined the Commissioner’s liability solely on the facts as alleged in Ly’s petition, and set the issue of mandamus damages for a fact trial. The Commissioner appealed the district court’s order, contending that she could immediately appeal the order before entry of final judgment. The court of appeals disagreed and dismissed the appeal for lack of jurisdiction.The Minnesota Supreme Court concluded that the basis for appeal from an order issuing a peremptory writ of mandamus under Rule 103.03(g) has been extinguished, and that appeal must instead proceed from a final judgment under Minn. R. Civ. App. P. 103.03(a). The court further concluded that an order issuing a peremptory writ is not appealable under Rule 103.03(a) as a form of irregular judgment, and that the district court order currently on appeal does not satisfy the finality requirement of that rule. However, the court invoked its inherent authority and its authority under Minn. R. Civ. App. P. 102 to suspend the final judgment requirement of Rule 103.03(a), reverse the decision of the court of appeals, exercise jurisdiction over the Commissioner’s underlying appeal, and remand to the court of appeals to consider the merits of the appeal. View "Ly v. Harpstead" on Justia Law

The case involves a lawsuit filed by Rosemary Lambert and Carolyn Hinzman, individually and as co-executors of the estate of Delmar P. Fields, against Eldercare of Jackson County, LLC, Community Health Association, and Dr. Irvin John Snyder. The plaintiffs allege that Mr. Fields contracted COVID-19 while a resident at Eldercare and died while under the care of Jackson General and Dr. Snyder. The defendants sought dismissal of the lawsuit, arguing that they were immune from liability under the COVID-19 Jobs Protection Act.The Circuit Court of Jackson County denied the defendants' motions to dismiss. The court interpreted the term "actual malice" in the COVID-19 Jobs Protection Act to mean that the defendant acted with the intent to injure or harm the plaintiff or decedent. The court found that the plaintiffs had alleged sufficient facts to survive a motion to dismiss.On appeal, the Supreme Court of Appeals of West Virginia affirmed the lower court's decision in part and reversed in part. The court held that the term "actual malice" in the COVID-19 Jobs Protection Act means that the defendant acted with the deliberate intent to commit an injury, as evidenced by external circumstances. The court found that the plaintiffs had alleged sufficient facts to show that Eldercare engaged in intentional conduct with actual malice. However, the court found that the allegations against Jackson General Hospital and Dr. Snyder were insufficient to establish that they engaged in intentional conduct with actual malice. The case was remanded for further proceedings. View "Eldercare of Jackson County, LLC v. Lambert" on Justia Law

Nicole Costin, individually and on behalf of her minor son, filed a lawsuit against Glens Falls Hospital and several of its staff members. Costin alleged that the hospital discriminated against her due to her substance-abuse disorder, violating the Americans with Disabilities Act and the Rehabilitation Act. She also raised state-law claims. Costin's allegations included the hospital conducting drug tests without informed consent, reporting her to the New York State Child Abuse and Maltreatment Register based on a false positive drug test, withholding pain relief, accelerating her labor without consent, and refusing to correct their actions.The United States District Court for the Northern District of New York dismissed Costin’s action, concluding that she failed to plausibly allege that she was discriminated against due to her disability. The district court also declined to exercise supplemental jurisdiction over her state-law claims.The United States Court of Appeals for the Second Circuit affirmed in part, vacated in part, and remanded the case for further proceedings. The court agreed with the lower court's dismissal of Costin’s claims related to the denial of an epidural, acceleration of labor, and treatment of her newborn. However, the court disagreed with the dismissal of Costin’s claims related to the hospital's instigation of a Child Protective Services investigation and its administration of a drug test. The court found that Costin had plausibly alleged that these actions were based on discriminatory policies, not medical decisions. The court also vacated the lower court's decision to decline supplemental jurisdiction over Costin’s state-law claims. View "Costin v. Glens Falls Hospital" on Justia Law

The case involves two petitioners, Daniel Dilly, Superintendent of the Rubenstein Juvenile Center (RJC), and Nancy Oldaker, Health Services Administrator at RJC, who were held in contempt of court by Judge Kurt Hall of the Circuit Court of Lewis County, West Virginia. The contempt charges arose from an incident involving a resident of RJC, identified as D.P., who suffered a broken jaw during a fight with other residents. The court had ordered that D.P. be taken off RJC grounds for an X-ray and that his mother be notified of his medical appointments. The court found that these orders were not adequately followed by the petitioners.The Circuit Court of Lewis County held a hearing to review D.P.'s placement and medical care, resulting in a "Medical Care Order" that directed RJC to schedule an appointment for D.P. with his oral surgeon and to allow D.P.'s mother to attend the appointment. The court also ordered RJC to provide a report concerning the incident that led to D.P.'s injury. When these orders were not fully complied with, the court held a "show cause" hearing and found both Superintendent Dilly and Ms. Oldaker in contempt of court, fining each of them $250.The Supreme Court of Appeals of West Virginia found that procedural errors in the lower court's contempt proceedings deprived the court of jurisdiction to impose such sanctions. The court noted that the lower court failed to provide the petitioners with adequate notice that they were facing indirect criminal contempt proceedings and did not afford them jury trials before imposing the fines. The court concluded that the contempt orders were void and granted the petitioners' requested writs of prohibition, thereby preventing the lower court from enforcing the contempt orders. View "State ex rel. Dilly v. Hall" on Justia Law

A class of individuals and businesses in Northern California, who paid health insurance premiums to certain health plans, sued Sutter Health, a healthcare system operator in the region. They alleged that Sutter abused its market power to charge supracompetitive rates to these health plans, which were then passed on to the class in the form of higher premiums. The case went to trial on claims under California’s Cartwright Act for tying and unreasonable course of conduct. The jury returned a verdict in favor of Sutter.The plaintiffs appealed, arguing that the district court erred by failing to instruct the jury to consider Sutter’s anticompetitive purpose and by excluding evidence of Sutter’s conduct before 2006. The United States Court of Appeals for the Ninth Circuit agreed with the plaintiffs. It held that the district court contravened California law by removing “purpose” from the jury instructions, and that the legal error was not harmless. The court also held that the district court abused its discretion under Federal Rule of Evidence 403 in excluding as minimally relevant all evidence of Sutter’s conduct before 2006. The court concluded that these errors were prejudicial and reversed the district court’s judgment, remanding the case for a new trial. View "SIDIBE V. SUTTER HEALTH" on Justia Law

The case revolves around Morgan Morales, who appealed against an administrative law judge's (ALJ) decision that she was not disabled and hence, not entitled to Social Security disability benefits. Morales claimed to suffer from several conditions, including bipolar disorder, depression, anxiety, ADHD, and narcolepsy. After being treated at a mental health center and starting on prescription medications, Morales reported that her conditions were in remission. The ALJ, however, denied her application for benefits, finding that her mental impairments were mild and did not limit her ability to perform basic work activities, including her past job as a material handler.Morales challenged the ALJ's decision in the United States District Court for the Southern District of Indiana, Indianapolis Division. She criticized the ALJ's decision about her functional capacity to work but failed to provide evidence compelling the conclusion that the adverse disability decision lacked substantial support in the record. The District Court upheld the ALJ's decision, stating that Morales had not carried her burden of proof and that the ALJ's decision was supported by substantial evidence.The case was then brought to the United States Court of Appeals for the Seventh Circuit. The court affirmed the lower court's decision, stating that Morales had misunderstood the burden she bore on appeal. The court noted that it was not enough to criticize the ALJ's decision; Morales needed to point to evidence compelling the conclusion that the adverse disability decision lacked substantial support in the record. The court also dismissed Morales's criticism of the District Court's decision, stating that the District Court had conducted an adequate review of the ALJ's determination and correctly applied the law. The court concluded that the ALJ's determination was reasonable and supported by substantial evidence, and therefore, affirmed the decision. View "Morales v. O'Malley" on Justia Law

The Supreme Court of Texas reviewed a case involving the State of Texas, Ken Paxton in his official capacity as Attorney General of Texas, the Texas Medical Board, and Stephen Brint Carlton in his official capacity as Executive Director of the Texas Medical Board (collectively, the State) against a group of women and physicians. The plaintiffs challenged the constitutionality of Texas's abortion laws, specifically the Human Life Protection Act, which generally prohibits performing an abortion except when a pregnant woman has a life-threatening physical condition that poses a risk of death or serious physical impairment unless an abortion is performed.The case reached the Supreme Court of Texas as a direct appeal from a temporary injunction issued by the 353rd District Court, Travis County, Texas, which halted the enforcement of Texas's abortion laws in various circumstances. The State contested the injunction, arguing that the plaintiffs lacked standing, the State had sovereign immunity, and the current Texas law permitting life-saving abortion was not more limiting than the Texas Constitution permits.The Supreme Court of Texas held that one of the plaintiffs, Dr. Damla Karsan, had standing to challenge the Attorney General’s enforcement of the Human Life Protection Act against her. The court also concluded that the Declaratory Judgments Act waives the State’s immunity for a claim that a statute violates the state constitution. The court further clarified that under the Human Life Protection Act, a woman with a life-threatening physical condition and her physician have the legal authority to proceed with an abortion to save the woman’s life or major bodily function, in the exercise of reasonable medical judgment and with the woman’s informed consent. The court concluded that Dr. Karsan had not demonstrated that the part of the Human Life Protection Act that permits life-saving abortion is narrower than the Texas Constitution allows. As a result, the court vacated the lower court's injunction order. View "State v. Zurawski" on Justia Law

The case involves four plaintiffs who took docetaxel, a chemotherapy drug, as part of their treatment for early-stage breast cancer and subsequently suffered permanent chemotherapy-induced alopecia (PCIA). The plaintiffs allege that the manufacturers of the drug, Hospira, Inc., Hospira Worldwide, LLC, and Accord Healthcare, Inc., violated state law by failing to warn them that docetaxel could cause PCIA.The case was initially heard in the United States District Court for the Eastern District of Louisiana, where the defendants moved for summary judgment on the basis that the plaintiffs' state law failure-to-warn claims were preempted by federal law. The district court denied the motion, and the defendants appealed.The United States Court of Appeals for the Fifth Circuit was tasked with determining whether federal law preempts the plaintiffs' state law failure-to-warn claims against the defendant drug manufacturers. The court found that the district court had erred in its interpretation of what constitutes "newly acquired information" under the changes-being-effected (CBE) regulation, which allows manufacturers to file a supplemental application with the FDA and simultaneously implement a labeling change before obtaining FDA approval. The court held that the district court failed to enforce the requirement that newly acquired information must "reveal risks of a different type or greater severity or frequency than previously included in submissions to FDA."The court vacated the district court's judgment on the plaintiffs' failure-to-warn claims and remanded the case for further consideration of one outstanding issue: whether the Bertrand Abstract, a scientific study, constituted "newly acquired information" that revealed a greater risk of PCIA than previously known. If the Bertrand Abstract does not meet this standard, the court held that the defendants would not be liable to the plaintiffs on their state law failure-to-warn claims. View "Hickey v. Hospira" on Justia Law