Justia Injury Law Opinion Summaries

A woman with dementia became a resident at a memory care facility in Montana in June 2021. She died in November 2021 after suffering infections and complications. Her son, acting both individually and as personal representative of her estate, filed suit against the facility and related entities in November 2023, alleging claims including wrongful death, negligence, infliction of emotional distress, elder abuse, unjust enrichment, and contract rescission. The claims centered on allegations that the facility’s staff failed to provide adequate care, leading to the woman’s injuries and death. The original complaint, and a subsequent first amended complaint filed in November 2024, were never served on any defendant.The Montana Eleventh Judicial District Court, Flathead County, dismissed all claims with prejudice in March 2025, finding that the son’s claims were medical malpractice actions subject to the two-year statute of limitations and six-month service requirement under Montana law. The court concluded that because the complaints were not timely served, and the amended complaint was filed after the statute of limitations had expired, the claims were time-barred. The court also rejected arguments that the filing of the original complaint tolled the statute or that the amended complaint related back to the original complaint.On appeal, the Supreme Court of the State of Montana held that the care-related claims (Counts I-VI) were medical malpractice claims subject to the statutory time limits and service requirements, and affirmed their dismissal as time-barred. However, the court found that the unjust enrichment and contract rescission claims (Counts VII and VIII) were not medical malpractice claims and were not subject to those limitations. The Supreme Court reversed the dismissal of those two counts and remanded for further proceedings solely on those claims. View "Estate of Athy v. Edgewood" on Justia Law

An information security executive was hired by a financial institution to improve its internal controls but was later terminated. During her tenure, a subordinate raised concerns about compliance, which led to an internal audit and ultimately contributed to the decision to fire her. She believed her firing was motivated by sex discrimination and defamatory statements made by colleagues regarding her job performance. She first filed a complaint with the Iowa Civil Rights Commission, then a federal lawsuit against her employer and several individuals, alleging discrimination, defamation, and other claims. Most of her claims, including defamation, were dismissed by the United States District Court for the Southern District of Iowa for failure to state a claim, and summary judgment was granted to the defendants on the remaining claims. She did not appeal.Several months after her federal lawsuit concluded, she filed a new defamation action in the Iowa District Court for Polk County against a different set of coworkers, based on statements and internal reports from more than three years prior. The defendants moved to dismiss, arguing that the claims were barred by Iowa’s two-year statute of limitations for injuries to reputation. The district court granted the motion to dismiss, finding that the limitations period began at publication or, alternatively, that she was on inquiry notice of the claims by the time she filed her first lawsuit.On appeal, the Iowa Court of Appeals reversed, holding that the discovery rule might apply to defamation claims and that factual issues about notice precluded dismissal. Upon further review, the Iowa Supreme Court vacated the appellate decision and affirmed the district court’s dismissal, holding that the plaintiff was on inquiry notice of her defamation claims more than two years before filing suit, so the claims were time-barred regardless of the discovery rule’s application. View "Betz v. Mathisen" on Justia Law

The plaintiff was involved in a car accident with the defendant, after which he sought damages for the diminished value and loss of use of his vehicle, alleging the accident was caused by the defendant’s negligence. The defendant’s insurer paid the full property damage coverage limit to the plaintiff’s insurer, based on the assertion that the plaintiff had been made whole. The plaintiff then amended his complaint to allege that his insurer was unjustly enriched for accepting the payment and exhausting the defendant’s coverage before the plaintiff was fully compensated, in violation of the make whole doctrine.The case was brought in the Superior Court for the judicial district of Hartford, which dismissed the unjust enrichment claim against the insurer, finding it was not ripe for adjudication. The court reasoned that the plaintiff’s claim depended on the outcome of his negligence action against the defendant. The plaintiff appealed, and the Connecticut Appellate Court affirmed the dismissal, concluding the unjust enrichment claim would only become ripe after the plaintiff obtained a judgment against the defendant and exhausted collection efforts, because the injury was contingent on whether and to what extent the plaintiff could recover and on the defendant’s ability to satisfy a judgment.On review, the Supreme Court of Connecticut held that the Appellate Court incorrectly affirmed the dismissal on ripeness grounds. The Supreme Court ruled that a claim based on premature subrogation in violation of the make whole doctrine is ripe for adjudication even before a judgment against the tortfeasor is obtained, because the alleged injury—violation of the plaintiff’s priority right to the defendant’s insurance coverage—had already occurred. The court also found the plaintiff had standing to assert his claim. The Supreme Court reversed the Appellate Court’s judgment and remanded for further proceedings. View "Orlando v. Liburd" on Justia Law

After experiencing medical complications following a delayed appendectomy, a nineteen-year-old patient brought a medical malpractice action against a hospital, its corporate affiliate, and several health care providers. The patient had gone to the hospital's emergency department with abdominal pain and other symptoms and was initially diagnosed with a urinary tract infection and discharged. She returned the next day with worsening pain, was diagnosed with acute appendicitis, and underwent surgery after a twelve-hour delay. The appendicitis had perforated, resulting in additional surgeries and complications, including abdominal abscess and pleural effusion, and a prolonged hospital stay.The patient filed her complaint in the Superior Court, alleging negligence and adverse consequences from delayed diagnosis and treatment. She moved to impound her medical records, arguing for their confidentiality, but the judge denied her motion, citing failure to show good cause and allowing her to refile with more specificity, which she declined. She also sought a protective order, which was similarly denied. For the medical malpractice tribunal process, the plaintiff submitted an expert opinion letter without her medical records. The tribunal found the offer of proof insufficient to raise a legitimate question of liability for judicial inquiry. The plaintiff failed to post the required bond within thirty days of the tribunal’s finding, resulting in dismissal of her claims. The Appeals Court affirmed both the dismissal and the denial of impoundment.On further appellate review, the Supreme Judicial Court of Massachusetts held that the judge did not abuse discretion in denying impoundment of the medical records, as the plaintiff failed to provide particularized information or establish good cause. The court also held that the medical malpractice tribunal did not err in finding the offer of proof insufficient, as it lacked specific information regarding each defendant’s conduct. The Supreme Judicial Court affirmed both the denial of the impoundment motion and the judgment of dismissal. View "DosSantos v. Beth Israel Deaconess Hospital-Milton, Inc." on Justia Law

An employee of a drywall supply company suffered a right ankle injury while carrying drywall sheets up a stairway in October 2019. The employer and its workers’ compensation insurer initially accepted the injury as compensable, providing medical care and temporary disability benefits. After an independent medical examination in January 2021 concluded the employee had reached maximum medical improvement, the insurer discontinued benefits. The employee continued to experience pain and pursued additional treatment, including surgery and further imaging, which ultimately revealed a recurrent tendon tear in the same ankle. Delays in authorizing necessary diagnostic procedures led to an 18-month gap before the recurrent tear was properly identified.Following the denial of benefits for additional treatment, the employee filed a workers’ compensation complaint with the Idaho Industrial Commission. The Commission held a bifurcated hearing addressing causation and entitlement to further medical care and temporary disability benefits. The Commission adopted its Referee’s findings, concluding that the employee had not proven by a preponderance of the evidence that the recurrent tendon tear was caused by the original workplace accident. The Commission reasoned that the recurrent tear was a new injury, not an aggravation of the original compensable injury, and denied the claim for continued benefits. The Commission also denied the employee’s motion for reconsideration, rejecting arguments regarding procedural due process and misapplication of the compensable consequences doctrine as explained in Sharp v. Thomas Brothers Plumbing.On appeal, the Supreme Court of the State of Idaho reversed the Commission’s decision. The Court held that the Commission erred by failing to apply the compensable consequences doctrine correctly to determine causation between the initial compensable injury and the subsequent recurrent tendon tear. The Court found that there was a demonstrable causal connection and that the Commission had improperly required the claimant to negate all other possible causes. The case was remanded for further proceedings, and the employee was awarded attorney fees and costs on appeal. View "Miklos v. L&W Supply" on Justia Law

A man named Jordan was incarcerated in the Madison County Jail in Iowa, where he exhibited signs of acute mental health distress, including a recent history of suicide attempts, hearing voices, and expressing thoughts of self-harm. His parents and girlfriend raised concerns about his mental state to jail staff. In response, Scott Thomas, a Jail Diversion Case Manager employed by Eyerly-Ball Community Mental Health Services, met with Jordan, who disclosed his mental health struggles and suicidal thoughts. Thomas reported to jail staff only that Jordan said he would not harm himself while in custody, omitting other serious statements. Ten minutes after being returned to his cell, Jordan died by suicide.The Paynes, Jordan’s parents, sued Thomas and Eyerly-Ball for negligence in the United States District Court for the Southern District of Iowa. The district court dismissed the federal claims and retained jurisdiction over the state-law claims. Later, the court granted summary judgment to Thomas and Eyerly-Ball on the negligence claims, holding that they owed no legal duty to Jordan under Iowa law and relevant sections of the Restatement (Third) of Torts.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo. The appellate court found that there were genuine disputes of material fact regarding whether Thomas and Eyerly-Ball undertook a duty to assess and communicate Jordan’s suicide risk and whether their actions increased the risk of harm or caused jail staff to rely on their assessment. The court held that, under Iowa law, summary judgment was inappropriate on the question of duty based on an undertaking. However, it agreed that no duty arose from a custodial relationship, as Thomas and Eyerly-Ball did not have custody of Jordan. The appellate court reversed the district court’s grant of summary judgment and remanded for further proceedings. View "Payne v. Eyerly-Ball" on Justia Law

The claimant suffered a workplace injury while lifting a box, resulting in immediate neck and shoulder pain. She promptly sought medical treatment and was diagnosed with a shoulder strain, receiving temporary disability benefits and performing light duty work. Over time, her symptoms persisted and evolved, leading to various medical evaluations, including imaging studies and independent medical exams. Disagreement arose between medical providers regarding the nature and cause of her cervical spine abnormalities, with one provider opining that a herniated disc at C6-7 was caused by the accident and recommending surgery, while others attributed her symptoms to mild degenerative changes not caused by the workplace incident.After exhausting benefits and undergoing surgical procedures outside of the worker’s compensation system, the claimant filed a complaint with the Idaho Industrial Commission seeking additional medical and disability benefits, asserting that her cervical condition was work-related. Following a hearing, the Commission weighed conflicting medical expert testimony and found some inconsistencies and possible exaggeration in the claimant’s symptom reporting. Ultimately, the Commission determined that the claimant had proven a shoulder injury from the accident but failed to establish, to a reasonable degree of medical probability, that her herniated disc or cervical spine condition was caused by the workplace event.The Supreme Court of the State of Idaho reviewed the Commission’s decision. Applying the standard that factual findings by the Commission will not be disturbed unless clearly erroneous, and that legal conclusions are subject to free review, the Court found substantial and competent evidence supporting the Commission’s denial of additional benefits for the cervical spine condition. The Court affirmed the Commission’s decision and held that neither party was entitled to attorney fees on appeal. View "Proulx v. Saveway Market, Inc." on Justia Law

The dispute arose from a tragic incident on January 14, 2022, when Marquise Webb and Richie Aaron, Jr. boarded an Amtrak train in Illinois. Although unrelated, both transferred to Amtrak’s River Runner train in Missouri, where Webb fatally shot Aaron without apparent motive during a scheduled stop. Amtrak prohibits firearms onboard, but does not routinely conduct passenger security screenings. After the shooting, Amtrak crew initially dismissed reports of gunfire as fireworks, and medical aid was rendered to Aaron at the next station, but he was pronounced dead shortly thereafter.Following these events, Breayonna Aaron, representing herself, her deceased husband, and their children, filed suit in the United States District Court for the Western District of Missouri against Amtrak for negligence, negligent hiring/training/supervision, and wrongful death, seeking substantial compensatory and punitive damages. Amtrak moved for judgment as a matter of law, but the court submitted the case to a jury, which found Amtrak liable and awarded both compensatory and punitive damages. After trial, Amtrak renewed its motion for judgment as a matter of law or, alternatively, sought a new trial or reduction in punitive damages. The district court denied Amtrak’s motions, but reduced the punitive damages award as constitutionally excessive.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of Amtrak’s motion for judgment as a matter of law de novo. It held that the plaintiffs failed to provide legally sufficient evidence of a duty or causation under any negligence theory presented, as Missouri law requires foreseeability of criminal acts for a duty to exist, and but-for causation for wrongful death. The appellate court reversed the district court’s denial of Amtrak’s motion for judgment as a matter of law and directed the entry of judgment for Amtrak, finding no basis for liability on the claims asserted. View "Aaron v. National Railroad Passenger Corporation" on Justia Law

Renee Jauregui brought a medical malpractice claim against Dr. Shannon J. Cothran, her OB/GYN, alleging that between May and October 2018 she repeatedly informed Dr. Cothran about a lump in her breast during pregnancy-related visits. Jauregui stated that Dr. Cothran dismissed her concerns, diagnosing a clogged milk duct and assuring her that the lump was normal and would resolve itself. At her postpartum visit in October 2018, Jauregui was told to monitor the lump and call if there were changes. When Jauregui noticed a change in July 2019, she returned for a follow-up in August, resulting in a diagnosis of metastatic breast cancer.The Circuit Court of Fairfax County granted Dr. Cothran’s plea in bar, finding that Jauregui’s claim was barred by the statute of limitations. The court determined there was neither a continuous nor substantially uninterrupted course of examination or treatment after October 2018, thus the continuing treatment rule did not apply. The court concluded that no ongoing physician-patient relationship existed regarding the breast lump after the October 2018 appointment.The Court of Appeals of Virginia reversed the trial court’s decision, holding that the continuing treatment rule does not require specific treatment and that Jauregui’s return in August 2019, pursuant to Dr. Cothran’s prior instructions, established a continuous and substantially uninterrupted course of examination for the same condition.On appeal, the Supreme Court of Virginia held that the trial court did not err in sustaining Dr. Cothran’s plea in bar. It clarified that the continuing treatment rule requires a mostly continuous physician-patient relationship regarding a specific malady, and found that the ten-month gap between appointments constituted a substantial interruption. The Supreme Court of Virginia reversed the Court of Appeals and reinstated the trial court’s judgment, holding that Jauregui’s claim was time-barred. View "Cothran v. Jauregui" on Justia Law

After moving out of their condominium due to mold, Brenda Lee Allen and her family stayed at the Ontario Airport Inn Hotel, owned by Anil Bhula Patel. After more than 30 days, Allen’s funds ran out, and she requested extra time to pay rent, which was refused by the hotel manager, Luis Mejia. On April 19, 2020, while Allen and her family were moving out, an altercation occurred involving Allen, Mejia, and Patel. Allen alleged that Patel forcibly entered her room, threw her belongings into the hallway, struck her, and pushed her against the wall, causing her to suffer posttraumatic stress disorder (PTSD) and other serious health issues.Allen filed suit against Patel and his company, seeking compensatory and punitive damages for battery, assault, and related claims. The Superior Court of San Bernardino County bifurcated the trial to separate liability and compensatory damages from punitive damages. The jury awarded Allen over $1 million in compensatory damages for battery and intentional infliction of emotional distress. Before the punitive damages phase, two jurors were unavailable, leading the trial court to declare a mistrial on that issue. Patel subsequently moved for a new trial, arguing attorney misconduct and other trial irregularities.The Court of Appeal of the State of California, Fourth Appellate District, Division Two, reviewed the case. The court conducted an independent review and found substantial evidence of misconduct by Allen’s attorney, including knowingly misleading statements about medical causation, introduction of prejudicial and inflammatory evidence, improper closing arguments violating the golden rule and reptile theory, and attacks on defense counsel’s character. The appellate court affirmed the trial court’s order granting a new trial on liability and compensatory damages, finding no abuse of discretion and concluding that the issue of punitive damages was moot. View "Allen v. Patel" on Justia Law