Justia Injury Law Opinion Summaries

Martin B. Sturdivant, an employee of the North Carolina Department of Public Safety, sustained a back injury while working as a corrections officer. The injury led to chronic back pain, and Sturdivant received temporary total disability payments through the workers' compensation system. As he approached the 500-week limit for these payments, he applied for extended compensation, claiming a total loss of wage-earning capacity.The North Carolina Industrial Commission denied Sturdivant's claim, concluding that he had not sustained a total loss of wage-earning capacity. The Commission interpreted this phrase to mean a total loss of the ability to earn wages in any employment. Sturdivant appealed to the North Carolina Court of Appeals, which rejected the Commission's interpretation. The Court of Appeals held that "total loss of wage-earning capacity" was synonymous with "total disability," incorporating a broader legal test.The Supreme Court of North Carolina reviewed the case and held that the phrase "total loss of wage-earning capacity" means the complete elimination of the capacity to earn any wages. The Court clarified that this phrase does not share the same legal meaning as "total disability." The Court found that the Industrial Commission's interpretation was correct and that the Commission's findings were supported by competent evidence. The Supreme Court modified the Court of Appeals' opinion to reject its statutory interpretation but otherwise affirmed the decision. View "Sturdivant v. Department of Public Safety" on Justia Law

Kristen Walker gave birth to her son Henry at Baptist St. Anthony’s Hospital under the care of Dr. Rhodesia Castillo. Henry required resuscitation after birth due to asphyxiation during labor and allegedly suffered a stroke. The Walkers sued the hospital and Dr. Castillo for negligence, claiming their actions caused Henry’s permanent neurologic injury. They provided expert reports from an obstetrician, a neonatologist, and a nurse to support their claims. The defendants challenged the qualifications of the experts and the sufficiency of the reports, arguing they did not adequately explain the standards of care, breaches, and causation.The trial court overruled the defendants’ objections and denied their motion to dismiss, finding the reports provided a fair summary of the experts’ opinions as required by the Texas Medical Liability Act. The Court of Appeals for the Seventh District of Texas reversed this decision, holding that the reports contained conclusory and incomplete language that did not sufficiently explain the cause of Henry’s brain injury.The Supreme Court of Texas reviewed the case and concluded that the expert reports sufficiently explained causation and that the trial court correctly rejected the defendants’ other challenges. The court found that the reports from Drs. Tappan and Null together explained how breaches of the standard of care by Dr. Castillo and the nurses caused Henry’s injury. The court also determined that the trial court did not abuse its discretion in overruling the defendants’ objections to the experts’ qualifications. Consequently, the Supreme Court of Texas reversed the Court of Appeals’ judgment and remanded the case to the trial court for further proceedings. View "Walker v. Baptist St. Anthony's Hospital" on Justia Law

Hemphill Construction Company, Inc. (Hemphill) entered into a contract with the City of Jackson and subsequently subcontracted Interstate Carbonic Enterprises (ICE) for a project. Gay Lynn Harris, Jr., an owner and officer of ICE, was severely injured while working on the project in September 2020. Harris sought workers’ compensation benefits from Hemphill, but an Administrative Judge (AJ) ruled that Harris was not entitled to these benefits because he had voluntarily opted out of ICE’s workers’ compensation insurance coverage. Neither party appealed the AJ’s decision.In March 2022, Harris filed a negligence complaint against Hemphill in the Circuit Court of the First Judicial District of Hinds County. Hemphill moved to dismiss the complaint, claiming tort immunity under the exclusive remedy provision of the Mississippi Workers’ Compensation Act (MWCA). The trial court agreed and granted Hemphill’s motion to dismiss. Harris appealed, arguing that tort immunity did not apply and that judicial estoppel should apply. Hemphill contended that Harris had not exhausted his administrative remedies.The Supreme Court of Mississippi reviewed the case and found that Harris was not required to exhaust his administrative remedies before filing his negligence suit. The court held that Hemphill was entitled to tort immunity because it had contractually required ICE to obtain workers’ compensation insurance for its employees, thus satisfying the statutory requirement to secure payment under the MWCA. The court affirmed the trial court’s decision to dismiss Harris’s negligence claim against Hemphill. View "Harris v. Hemphill Construction Company, Inc." on Justia Law

Angel Matta was hired by Dakota Provisions in February 2020 as a production worker. Matta had attendance issues documented by his employer and was injured at work on March 23, 2020, leading to several weeks of missed work. He filed a workers' compensation claim and was terminated by Dakota Provisions one month later. Matta then filed a lawsuit alleging wrongful termination and violation of public policy. Dakota Provisions moved for summary judgment, which the circuit court granted. Matta appealed the decision.The Circuit Court of the Third Judicial Circuit in Beadle County, South Dakota, reviewed the case. The court granted summary judgment in favor of Dakota Provisions, concluding that Matta was an at-will employee and could be terminated for any lawful reason. The court also found that Matta failed to exhaust administrative remedies for his disability discrimination claim and did not recognize a common law tort for retaliatory discharge based on a disability.The Supreme Court of the State of South Dakota reviewed the case. The court affirmed the circuit court's decision in part, agreeing that Matta was an at-will employee and that his termination did not violate public policy based on disability discrimination. However, the court reversed the summary judgment regarding Matta's claim of retaliatory discharge for filing a workers' compensation claim. The court found that there were genuine issues of material fact regarding whether Matta's termination was pretextual and retaliatory, given the proximity of his termination to his workers' compensation claim and the inconsistent reasons provided by Dakota Provisions for his termination. The case was remanded for further proceedings on this claim. View "Matta v. Dakota Provisions" on Justia Law

Dionicio Rodriguez, an employee of SIR Electric LLC (SIR), was injured while working and filed for workers' compensation benefits under SIR's policy with Hartford Underwriters Insurance Company (Hartford). After receiving benefits, Rodriguez filed a personal injury lawsuit against SIR, alleging negligence, gross negligence, recklessness, and intentional wrongdoing. SIR requested Hartford to defend against the lawsuit, but Hartford refused, citing policy exclusions. SIR then filed a third-party complaint against Hartford, claiming wrongful disclaimer of defense coverage.The trial court granted Hartford's motion to dismiss SIR's complaint, ruling that the policy excluded intent-based claims. SIR's motion for reconsideration and to amend its complaint, arguing that the policy's enhanced intentional injury exclusion (EII exclusion) violated public policy, was denied. The Appellate Division affirmed the trial court's decision.The Supreme Court of New Jersey reviewed the case and held that Hartford has no duty to defend SIR. The court determined that Rodriguez's claims of negligence, gross negligence, and recklessness are subject to the workers' compensation exclusivity bar and are not covered under Part One of the policy. These claims are also excluded from coverage under Part Two of the policy. Additionally, Rodriguez's claims of intentional wrongdoing are excluded under the policy's EII exclusion.The court concluded that the trial judge properly denied SIR's motion to amend its third-party complaint, as the EII exclusion does not violate public policy. The court affirmed the Appellate Division's judgment, upholding the dismissal of SIR's third-party complaint against Hartford. View "Rodriguez v. Shelbourne Spring, LLC" on Justia Law

Matthew Cartia and Autumn Adams were arrested by officers when they attempted to interfere with a police investigation at Cartia's parents' house. The officers claimed that Cartia and Adams were interfering with their work, leading to a confrontation where Cartia was handcuffed and taken down using a "hip-toss" maneuver. Adams was also arrested after she tried to intervene. Both Cartia and Adams alleged that the officers used excessive force during and after their arrests, including claims that Cartia was struck and choked by the officers.The United States District Court for the Eastern District of Missouri granted summary judgment in favor of the defendants, including the officers and Lincoln County. The magistrate judge concluded that the officers were entitled to qualified immunity and that Lincoln County was not liable under Monell for the officers' actions.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the grant of summary judgment for some claims but reversed it for others. The court held that the officers were entitled to qualified immunity for most of their actions, including the initial takedown and restraint of Cartia, as well as the force used against Adams. However, the court found that there were genuine issues of material fact regarding the excessive force claims against Officers Beeman and Gugliano for allegedly striking and choking Cartia after he was subdued. These claims were remanded for further proceedings. The court also found that the state law claims of assault and battery and negligence against these officers should proceed to trial, as there was sufficient evidence to suggest they may have acted with malice or bad faith. The court affirmed the dismissal of the remaining claims. View "Cartia v. Beeman" on Justia Law

A group of city and county governments, Indian tribes, and other entities filed actions against opioid manufacturers, distributors, and pharmacies, alleging they misled medical professionals and the public, leading to widespread addiction. Two Ohio counties, Trumbull and Lake, claimed that national pharmaceutical chains, including Walgreens, CVS, and Walmart, contributed to the opioid epidemic by filling prescriptions without proper controls. They filed a common-law absolute public-nuisance claim seeking equitable relief.The United States District Court for the Northern District of Ohio denied the pharmacies' motion to dismiss, which argued that the Ohio Product Liability Act (OPLA) abrogated the public-nuisance claims. The court based its decision on a prior ruling in a related case, concluding that the OPLA did not abrogate public-nuisance claims seeking non-compensatory damages. After a jury verdict in favor of the counties, the pharmacies' motion for judgment as a matter of law was also denied. The pharmacies appealed, and the Sixth Circuit certified a question to the Supreme Court of Ohio regarding the OPLA's scope.The Supreme Court of Ohio held that the OPLA abrogates all common-law public-nuisance claims arising from the sale of a product, including those seeking equitable relief. The court determined that the statutory definition of "product liability claim" includes public-nuisance claims related to the design, manufacture, supply, marketing, distribution, promotion, advertising, labeling, or sale of a product. The court rejected the argument that the OPLA only abrogates claims seeking compensatory damages or involving defective products. The court concluded that the counties' claims, based on the pharmacies' dispensing of opioids, fall within the scope of the OPLA and are therefore abrogated. View "In re Natl. Prescription Opiate Litigation" on Justia Law

A medical-malpractice action was filed by Kalvyn Stull and his family against Summa Health System and associated parties, alleging that improper medical treatment following a car accident caused severe brain damage to Kalvyn. During discovery, the plaintiffs requested the residency file of Dr. Mazen Elashi, a resident physician involved in the treatment. Summa Health System claimed the file was protected by the peer-review privilege under Ohio law, supported by an affidavit from Dr. Erika Laipply, which stated that the file was used exclusively for peer-review purposes.The trial court in Summit County held that Summa had not sufficiently demonstrated that the peer-review privilege applied, as the affidavit contained ambiguities and lacked specific details. The court granted the motion to compel the production of the residency file. Summa appealed, and the Ninth District Court of Appeals affirmed the trial court's decision, agreeing that the affidavit was insufficient to establish the privilege due to its ambiguities and incomplete information.The Supreme Court of Ohio reviewed the case and held that the presence of factual ambiguities in affidavit testimony does not alone determine whether the peer-review privilege applies. The court emphasized that the trial court has the authority to conduct further inquiry, including in camera review, to resolve the factual disputes and determine the applicability of the privilege. The Supreme Court reversed the judgment of the Ninth District Court of Appeals and remanded the case to the trial court for an in camera review of the residency file and any other necessary factual inquiry to resolve the legal question of whether the file is privileged. View "Stull v. Summa Health System" on Justia Law

The case involves a medical malpractice suit brought by the parents of a stillborn child against the midwives who attended the birth. The plaintiffs alleged that the midwives failed to obtain informed consent for delivery by midwife at a birth center instead of by a physician at a hospital. They claimed the midwives did not disclose the risks associated with midwife delivery for an expectant mother of advanced maternal age with a history of miscarriage. The superior court granted summary judgment in favor of the midwives, ruling that the plaintiffs failed to present evidence that midwife delivery caused the stillbirth.The superior court found that the plaintiffs did not provide sufficient evidence to establish proximate cause, a necessary element in informed consent claims. The court noted that the plaintiffs needed to show both that they would not have consented to the treatment if properly informed and that the treatment caused the injury. The midwives presented expert testimony indicating that their care did not cause the stillbirth, and the plaintiffs failed to rebut this with their own expert evidence.The Supreme Court of the State of Alaska reviewed the case and affirmed the superior court's summary judgment in favor of the midwives. The court held that the plaintiffs did not present admissible evidence to dispute the midwives' expert opinion that the stillbirth was caused by an infection unrelated to the midwives' care. The court also affirmed the superior court's award of enhanced attorney’s fees to the midwives, finding that the plaintiffs engaged in vexatious or bad faith conduct during the litigation. The court concluded that the plaintiffs' failure to provide necessary expert testimony on causation was fatal to their claims. View "Goodwin v. Mat-Su Midwifery, Inc." on Justia Law

Michael Boren applied for a conditional use permit (CUP) to have an unimproved airstrip on his property recognized as a designated county airstrip. Gary Gadwa, Sarah Michael, and other concerned citizens opposed Boren’s application, but it was ultimately approved. Following the approval, Boren sued Gadwa, Michael, and others for defamation, defamation per se, conspiracy to commit defamation, and declaratory relief, alleging they made false statements about the airstrip and his use of it. Boren filed an amended complaint, and Gadwa and Michael moved to dismiss the claims, arguing their statements were protected by litigation privilege and constitutionally protected petitioning activity.The District Court of the Seventh Judicial District of Idaho dismissed Boren’s claims, agreeing with Gadwa’s and Michael’s arguments. The court also denied Boren’s motion to file a second amended complaint, concluding it would be futile. Boren appealed the district court’s decisions.The Supreme Court of Idaho reviewed the case and affirmed the district court’s dismissal of Boren’s civil conspiracy claim and declaratory judgment claim. However, it reversed the dismissal of most of Boren’s defamation claims, finding that the applicability of the absolute and qualified litigation privileges was not evident on the face of the complaint. The court also held that neither the First Amendment nor the Idaho Constitution provides absolute protection for defamatory statements made in the course of protected petitioning activity. The court reversed the district court’s decision denying Boren’s motion to amend his complaint, as the amendment would not be futile. The case was remanded for further proceedings consistent with the opinion. The court declined to disqualify the district judge on remand and did not award attorney fees to any party. View "Boren v. Gadwa" on Justia Law