Justia Injury Law Opinion Summaries

Dr. William Partin filed a lawsuit against Baptist Healthcare System, Inc. and Dr. Daniel Eichenberger after he resigned from his position. Partin alleged that Baptist and Eichenberger retaliated against him in violation of the Emergency Medical Treatment and Active Labor Act (EMTALA) and brought claims under Indiana law for breach of contract, tortious interference with contractual relations, and defamation. The dispute arose from Partin's treatment of a suicidal patient, J.C., in Baptist's emergency department, where Partin ordered procedures against J.C.'s will, leading to complaints from hospital staff.The United States District Court for the Southern District of Indiana granted summary judgment in favor of Baptist and Eichenberger. The court found that no reasonable jury could conclude that Partin engaged in EMTALA-protected activity or that he was retaliated against for such activity. The court also determined that Partin's breach of contract claim failed because the bylaws did not create a contractual relationship between Partin and Baptist, and his resignation was not under duress. Additionally, the court found no evidence to support Partin's claims of tortious interference with contract or defamation.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that Partin did not engage in EMTALA-protected activity and that his belief in reporting a potential EMTALA violation was not objectively reasonable. The court also agreed that the bylaws did not create a contract between Partin and Baptist and that Partin's resignation was voluntary. Furthermore, the court found that Baptist's actions were justified and not malicious, and that the statements made by Eichenberger and Marksbury were protected by qualified privilege and not made in bad faith. View "Partin v Baptist Healthcare System, Inc." on Justia Law

Sydney Walton, a fourteen-year-old, suffered a concussion and other head injuries during an indoor soccer practice at a Baltimore County-owned facility. The plaintiffs, her family, alleged that the defendants, including Premier Soccer Club, Inc., its coach, and several Baltimore County employees, were negligent in violating a Maryland statute designed to ensure that parents, players, and coaches in youth sports are informed about the risks of concussions and best practices for preventing and handling them.The Circuit Court for Baltimore County granted summary judgment in favor of the defendants on the negligence claim based on the statutory violation. The court found that the plaintiffs failed to provide evidence that the alleged statutory violations proximately caused Sydney's injuries. The plaintiffs appealed, but the Appellate Court of Maryland affirmed the circuit court's decision, agreeing that the plaintiffs did not establish the necessary causation-in-fact.The Supreme Court of Maryland reviewed the case and affirmed the judgment of the Appellate Court. The court held that to establish a prima facie case of negligence based on a statutory violation, the plaintiff must show that the defendant violated a statute designed to protect a specific class of persons that includes the plaintiff and that the violation proximately caused the plaintiff's injury. The court emphasized that proximate cause requires evidence of both causation-in-fact and legal causation. The plaintiffs failed to provide sufficient evidence to establish that the statutory violations were the cause-in-fact of Sydney's injuries, and thus, the summary judgment in favor of the defendants was upheld. View "Walton v. Premier Soccer Club" on Justia Law

In 2003, Sarah Ramey underwent a urethral dilation performed by Dr. Edward Dunne, which resulted in severe pain and subsequent debilitating medical conditions. Over the next fourteen years, Ramey sought medical advice from numerous doctors to determine the cause of her ailments. In 2017, Drs. Mario Castellanos and Lee Arnold Dellon linked her symptoms to the 2003 procedure. Ramey filed a lawsuit against Dr. Dunne and Foxhall Urology in 2019.The Superior Court of the District of Columbia held a bifurcated trial to determine if Ramey’s claim was barred by the statute of limitations. The jury found that Ramey failed to file her suit within the three-year statute of limitations. Ramey then filed a motion for judgment as a matter of law or, alternatively, for a new trial, arguing that the trial court erred in its rulings and jury instructions. The trial court denied her motion.The District of Columbia Court of Appeals reviewed the case. The court held that the trial court did not err in denying Ramey’s motion for judgment as a matter of law, as there was sufficient evidence for a reasonable jury to find that Ramey had received medical opinions linking her symptoms to the urethral dilation before 2017. The court also found that Ramey waived her claim regarding the jury instructions by affirmatively agreeing to them during the trial.However, the Court of Appeals held that the trial court erred in not granting a new trial based on the improper invocation of inquiry notice by appellees’ counsel during rebuttal closing arguments. The court found that the trial court’s corrective instruction was insufficient to mitigate the prejudicial impact of the improper argument. Consequently, the case was remanded for a new trial. View "Ramey v. Foxhall Urology, Chartered" on Justia Law

New England Country Foods, LLC (NECF) alleged that VanLaw Food Products, Inc. (VanLaw) intentionally undercut its business by promising to replicate NECF’s popular barbeque sauce and sell it directly to Trader Joe’s. NECF sued VanLaw in federal court, claiming tortious interference and other claims. The district court dismissed the case based on a clause in their manufacturing contract that limited damages. The United States Court of Appeals for the Ninth Circuit asked the California Supreme Court whether a contract clause that substantially limits damages for intentional wrongdoing is invalid under Civil Code section 1668.The district court dismissed NECF’s complaint, reasoning that the contract allowed only for direct damages and injunctive relief, while NECF sought lost profits, attorneys’ fees, and punitive damages. The court rejected NECF’s argument that section 1668 prevents limiting damages for future intentional conduct, stating it only prevents contracts that completely exempt parties from liability. NECF amended its complaint, but the district court dismissed it with prejudice, citing that parties may limit liability for breach of contract and that the contract did not bar all money damages but limited them to specific types NECF did not suffer. NECF appealed, and the Ninth Circuit sought guidance from the California Supreme Court.The California Supreme Court held that limitations on damages for willful injury to the person or property of another are invalid under section 1668. The court reasoned that the statute’s language and purpose, along with the policy against willful tortious conduct, support this interpretation. The court clarified that section 1668 does not preclude parties from limiting liability for pure breaches of contract absent a violation of an independent duty. The court’s decision ensures that parties cannot contractually limit their liability for intentional torts. View "New England Country Foods v. Vanlaw Food Products" on Justia Law

Two former police officers, Mark Zukowski and Joshua Ruggiero, were injured in the line of duty and subsequently awarded both accidental disability retirement (ADR) benefits and workers' compensation benefits. The ADR benefits exceeded the workers' compensation benefits, resulting in an offset of the latter. The key issue in this case was whether attorney’s fees should be calculated before or after applying the statutory offset under Maryland’s Workers’ Compensation Act.The Maryland Workers’ Compensation Commission awarded Zukowski and Ruggiero workers' compensation benefits, but these were largely offset by their ADR benefits. The Commission calculated attorney’s fees based on the reduced, post-offset amount of workers' compensation benefits. Zukowski and Ruggiero argued that attorney’s fees should be calculated based on the total award before applying the offset, contending that the terms "compensation" and "benefits" in the relevant statutes should be interpreted differently.The Circuit Court for Anne Arundel County affirmed the Commission’s decision, agreeing that attorney’s fees should be calculated after applying the offset. The court found no distinction between "compensation" and "benefits" in this context and held that attorney’s fees are a lien on the compensation actually payable to the claimant.The Supreme Court of Maryland reviewed the case and affirmed the lower courts' decisions. The Court held that the terms "compensation" and "benefits" are interchangeable in this context, meaning that attorney’s fees should be calculated based on the amount of workers' compensation benefits payable after applying the statutory offset. The Court emphasized that the attorney’s fees are a lien on the compensation awarded, which is the amount actually payable to the claimant after the offset. The Court also rejected the argument that this interpretation was unconstitutional, noting that attorneys voluntarily enter into contingency fee arrangements and are aware of the statutory framework governing such fees. View "Zukowski v. Anne Arundel Cnty." on Justia Law

A landlord operated a business renting homes and had a tenant who performed repair, maintenance, and improvement work in exchange for reduced rent and payment. The tenant fell while working on the roof of one of the rental units and filed a workers' compensation claim. The landlord denied an employment relationship and disputed the work-related injury.The Director of the Department of Labor and Industrial Relations ruled in favor of the tenant, finding an employer-employee relationship. The landlord appealed, and the Labor and Industrial Relations Appeals Board (LIRAB) reversed the Director's decision, concluding there was no employment relationship under the control and relative nature of work tests. The tenant appealed to the Intermediate Court of Appeals (ICA), which vacated parts of LIRAB's decision, instructing LIRAB to apply the substantial evidence standard instead of the preponderance of the evidence standard.The Supreme Court of the State of Hawai'i reviewed the case. The court held that the landlord did not present substantial evidence to rebut the presumption of an employment relationship under the relative nature of the work test. The tenant's work was integral to the landlord's rental business, and the tenant did not have a business of his own. Therefore, the court concluded that an employer-employee relationship existed, and the tenant's injury was covered under Hawai'i's workers' compensation laws. The court vacated LIRAB's decision and the ICA's judgment, remanding the case to LIRAB to compute compensation. The court also held that the landlord was not responsible for the tenant's attorney fees and costs. View "Borrson v. Weeks" on Justia Law

In April 2018, Kiera Isgrig, a college student, was injured when a window and its casing fell on her while she was studying in a room at Indiana University. There was no direct evidence explaining why the window fell. Kevin Ashley, a university carpenter, found no defects that would have caused the window to fall without warning, although two sash springs were broken. The window had been last serviced in March 2017.The Monroe Circuit Court granted summary judgment in favor of the Trustees of Indiana University, finding that Isgrig failed to make a prima facie case of negligence under the premises liability standard. The court held that the university did not have actual or constructive knowledge of any issues with the window and that the doctrine of res ipsa loquitur did not apply.The Indiana Court of Appeals reversed and remanded, finding that the doctrine of res ipsa loquitur could apply to fixtures in premises liability cases. The court determined that a window falling out of a wall without interaction is not an event that typically occurs absent negligence and that there was sufficient evidence that the university had exclusive control over the window.The Indiana Supreme Court reviewed the case and held that the doctrine of res ipsa loquitur can be applied to premises liability cases involving fixtures. The court found that Isgrig presented sufficient evidence to create a genuine issue of material fact regarding the university's negligence. The court concluded that the window was under the exclusive control of the university and that such an incident would not normally occur without negligence. The court reversed the summary judgment and remanded the case for further proceedings. View "Isgrig v. Trustees of Indiana University" on Justia Law

Plaintiff Zackary Diamond was injured by a punch from a third party during an altercation in the restricted pit area at Bakersfield Speedway. He alleged that the defendants, Scott Schweitzer, Schweitzer Motorsports Productions, and Christian Schweitzer, were negligent in providing security, responding to the altercation, and undertaking rescue efforts. Defendants moved for summary judgment, arguing that Diamond's claims were barred by a release and waiver of liability form he signed to enter the pit area. The trial court granted the motion, finding the release clear, unequivocal, and broad in scope, covering the negligent conduct alleged.The Superior Court of Kern County granted summary judgment in favor of the defendants, concluding that the release included risks related to racing activities and that the assault was such a risk. The court interpreted the release as covering the type of event that occurred, thus barring Diamond's negligence claims.On appeal, Diamond contended that the release was unenforceable because the injury-producing act was not reasonably related to the purpose of the release, which he described as observing the race from the pit area. The Court of Appeal of the State of California, Fifth Appellate District, concluded that the release met the requirements for enforceability: it was clear, unambiguous, and explicit in expressing the intent to release all liability for Diamond's injury; the alleged acts of negligence were reasonably related to the purpose of the release; and the release did not contravene public policy. The court also found that the defendants adequately raised a complete defense based on the signed release and that Diamond failed to rebut this defense. Consequently, the court affirmed the summary judgment in favor of the defendants. View "Diamond v. Schweitzer" on Justia Law

Reyna Cruz slipped and fell in a Costco food court, injuring her neck, back, knee, and wrist, which led to back surgery. The incident was recorded by Costco’s surveillance cameras. The video showed no evidence of a smoothie spill or any customer purchasing a smoothie in the 28 minutes before Cruz’s fall. However, a woman with a child in a shopping cart was seen in the area shortly before the fall, and Cruz testified that she saw a pink substance on the floor, her shoe, and her pant leg after the fall. Costco employees who arrived at the scene did not recall seeing anything on the floor but cleaned the area and placed a “wet floor” sign. The manager’s incident report noted “smoothie drops” on the floor.Cruz filed a lawsuit in state court, which Costco removed to federal court. The United States District Court for the Northern District of Illinois granted summary judgment to Costco, concluding that Cruz had not provided evidence that the smoothie spill was on the floor long enough for Costco to have constructive notice of its presence. The court also found that Cruz did not present evidence that Costco maintained a policy leading to dangerous conditions.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court found that Cruz presented sufficient evidence to create genuine issues of material fact regarding the presence and duration of the smoothie spill. The court noted that the surveillance video, viewed in the light most favorable to Cruz, could allow a reasonable jury to infer that the spill had been on the floor for at least 28 minutes, which could establish constructive notice. The court also found that Cruz did not provide sufficient evidence to show that Costco maintained a pattern of dangerous conditions.The Seventh Circuit reversed the district court’s summary judgment and remanded the case for further proceedings. View "Cruz v Costco Wholesale Corporation" on Justia Law

In 2018, a $200 million mixed-use development project at Louisiana State University experienced issues with its fire-protection sprinkler systems, which began to crack and leak. Allied World National Assurance Company, which paid over $10 million for system replacements, sued Nisus Corporation in 2021, alleging that Nisus falsely represented its product's compatibility with the pipe material, leading to the damage.The United States District Court for the Middle District of Louisiana granted summary judgment in favor of Nisus, concluding that Allied's claims were time-barred under Louisiana law. The court found that while Provident, the insured party, did not have actual or constructive knowledge of the cause of the damage, RISE Residential, Provident's agent, had constructive knowledge of the cause by November 2019. This knowledge was imputed to Provident, starting the prescription period.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo and affirmed the district court's decision. The court held that RISE Residential's constructive knowledge of the sprinkler system issues, which was imputed to Provident, triggered the running of the prescription period well before July 23, 2020. The court also found that Nisus did not prevent Allied from timely availing itself of its causes of action, as a reasonable inquiry by RISE Residential would have uncovered the necessary information. Therefore, Allied's claims were prescribed, and the summary judgment in favor of Nisus was affirmed. View "Allied World National v. Nisus" on Justia Law