Justia Injury Law Opinion Summaries

Lavonne S. Mottern died after receiving a contaminated intravenous injection at Princeton Medical Center, operated by Baptist Health System, Inc. (BHS). Donald J. Mottern, as administrator of Lavonne's estate, filed claims against BHS, Meds I.V., LLC (the manufacturer of the injection), and three individuals associated with Meds I.V. The claims against Meds I.V. and the individuals were settled, leaving only the claims against BHS, which included negligence, wantonness, a claim under the Alabama Extended Manufacturer's Liability Doctrine (AEMLD), and a breach of implied warranty under the Uniform Commercial Code (UCC).The Jefferson Circuit Court dismissed all of Mottern's claims against BHS, including the negligence and wantonness claims, which BHS conceded should not have been dismissed. BHS argued that the AEMLD and UCC claims were subject to the Alabama Medical Liability Act (AMLA) and required proof of a breach of the standard of care. The trial court agreed and dismissed these claims, leading to Mottern's appeal.The Supreme Court of Alabama reviewed the case and agreed with BHS that all of Mottern's claims, including those under the AEMLD and UCC, are subject to the AMLA's standard-of-care provisions. The court held that the AMLA applies to all actions for medical injury, regardless of the theory of liability, and requires proof of a breach of the standard of care. The court reversed the trial court's dismissal of the negligence and wantonness claims and remanded the case for further proceedings consistent with its opinion. The main holding is that the AMLA's standard-of-care provisions apply to all claims alleging medical injury, including those under the AEMLD and UCC. View "Mottern v. Baptist Health System, Inc." on Justia Law

A Florida resident, Sheri Sawyer, acting as the personal representative of her deceased son Thomas's estate, filed a product-liability lawsuit against Cooper Tire & Rubber Company in the Mobile Circuit Court. The case arose from a fatal single-vehicle accident in Mobile County, Alabama, where a tire manufactured by Cooper Tire allegedly experienced tread separation, causing the vehicle to crash. The tire was purchased in Alabama by Barbara Coggin, the mother of the driver, Joseph Coggin, both Alabama residents.Cooper Tire moved to dismiss the case, arguing that Alabama courts lacked specific personal jurisdiction over it due to insufficient suit-related contacts with Alabama. Sawyer countered that Cooper Tire's extensive business activities in Alabama, including the sale, distribution, and advertising of the tire model in question, established sufficient contacts. While the motion was pending, the U.S. Supreme Court decided Ford Motor Co. v. Montana Eighth Judicial District Court, which held that specific personal jurisdiction could exist even without a direct causal link between the defendant's forum activities and the plaintiff's claims.The Mobile Circuit Court granted Cooper Tire's motion to dismiss, concluding that Sawyer failed to show that Cooper Tire sold, distributed, or marketed the specific tire model in Alabama within three years before the accident. The court also noted that neither Sawyer nor her son were Alabama residents, reducing Alabama's interest in providing a forum for the case. Sawyer appealed the decision.The Supreme Court of Alabama reversed the lower court's decision, applying the analytical framework from Ford. The court held that Cooper Tire's sale, distribution, and advertising of the tire model in Alabama "related to" Sawyer's claims, establishing specific personal jurisdiction. The court also found that the trial court's focus on the timing of Cooper Tire's contacts and Sawyer's residency was not dispositive. The case was remanded for further proceedings consistent with this opinion. View "Sawyer v. Cooper Tire & Rubber Company" on Justia Law

Steve Wynn, a prominent figure in Nevada gaming and politics, filed a defamation lawsuit against The Associated Press (AP) and its reporter, Regina Garcia Cano. The lawsuit stemmed from an article published by AP that reported on allegations of sexual assault against Wynn from the 1970s. The article was based on complaints obtained from the Las Vegas Metropolitan Police Department. Wynn claimed the allegations were false and that AP published the article with actual malice.The Eighth Judicial District Court in Clark County granted AP's special motion to dismiss under Nevada's anti-SLAPP statutes, which are designed to protect free speech and petitioning activities from meritless lawsuits. The district court found that the article was a good faith communication related to an issue of public concern and that Wynn failed to show a probability of prevailing on his defamation claim. Wynn appealed this decision.The Supreme Court of Nevada reviewed the case de novo. The court affirmed the district court's decision, holding that AP met its burden under the first prong of the anti-SLAPP analysis by showing the article was a good faith communication on a matter of public interest. The court also clarified that under the second prong, a public figure plaintiff must provide sufficient evidence for a jury to reasonably infer, by clear and convincing evidence, that the publication was made with actual malice. Wynn failed to meet this burden, as his evidence did not demonstrate that AP published the article with knowledge of its falsity or with reckless disregard for the truth. Consequently, the Supreme Court of Nevada affirmed the district court's order granting the special motion to dismiss. View "Wynn v. The Associated Press" on Justia Law

In this case, Tiffany Bingham challenged the constitutionality of the Utah Health Care Malpractice Act’s four-year statute of repose after her medical malpractice claim against Dr. George C. Gourley and Dr. McKay L. Platt was dismissed. Bingham underwent surgeries in 2010, experienced complications, and discovered in 2017 that the surgeries had caused damage, leading to the removal of her kidney. She filed her lawsuit in 2020, more than four years after the alleged malpractice, prompting the dismissal of her claim under the statute of repose.The Fourth District Court in Provo dismissed Bingham’s complaint, concluding that the statute of repose was constitutional. The court found that the statute did not violate the Open Courts Clause, the Uniform Operation of Laws Provision, or the Equal Protection Clause. The court reasoned that the statute was a non-arbitrary means of addressing the social and economic issues related to rising medical malpractice insurance costs and was reasonably necessary to achieve the legislative goal of stabilizing insurance premiums.The Utah Supreme Court affirmed the lower court’s decision. The court held that Bingham failed to demonstrate that the statute of repose violated the Open Courts Clause, as the legislature’s findings of a health care crisis were fairly debatable and the statute was a reasonable means to address that crisis. The court also found that the statute did not violate the Uniform Operation of Laws Provision, as it was reasonably necessary to achieve the legislative goals and actually and substantially furthered those goals. Finally, the court concluded that the statute did not violate the Equal Protection Clause, as it was rationally related to a legitimate public purpose and did not impair a fundamental right. View "Bingham v. Gourley" on Justia Law

The case involves a medical negligence claim brought by Janet Hild, the administrator of Scott Boldman's estate, against several medical professionals and entities, including Samaritan Health Partners and Good Samaritan Hospital. Boldman, who had multiple health issues, underwent an emergency appendectomy at Good Samaritan Hospital. Post-surgery, he became combative and removed his breathing tube, after which he soon died. Hild claimed that the anesthesia was improperly handled, causing Boldman's aggressive behavior and subsequent death. The hospital argued that Boldman self-extubated and suffered a cardiac arrest unrelated to the anesthesia.The case proceeded to a jury trial in the Montgomery County Court of Common Pleas. The jury found that Sandra Ward, the Certified Registered Nurse Anesthetist, was negligent in her care of Boldman. However, only the six jurors who found negligence were allowed to vote on whether Ward's negligence proximately caused Boldman's death. They concluded it did not. Hild filed a motion for a new trial, arguing that all jurors should have been allowed to vote on proximate cause. The trial court denied the motion.The Second District Court of Appeals reversed the trial court's decision in part, holding that the trial court erred by not allowing all jurors to vote on proximate cause, and remanded the case for a new trial on specific issues. The hospital appealed to the Supreme Court of Ohio.The Supreme Court of Ohio held that the same-juror rule applies in all negligence cases where the jury answers sequential interrogatories that separate the elements of negligence. This means the same three-fourths of jurors must concur on all elements for a valid verdict. The court reversed the Second District's decision to the extent it ordered a new trial and reinstated the jury's verdict in favor of the hospital. View "Hild v. Samaritan Health Partner" on Justia Law

Candace Hensley sustained injuries from a trip and fall accident at a Westin Hotel in Indianapolis, Indiana, on May 2, 2017. She and her husband, Timothy Hensley, filed a lawsuit in the State Court of Gwinnett County, Georgia, against Westin Hotel and Westin Hotel Management, L.P. (WHM), alleging negligence and loss of consortium. Merritt Hospitality, LLC (Merritt) and WHM responded, asserting that Merritt was incorrectly named and that Westin Hotel was not a legal entity. The Hensleys amended their complaint to include Merritt and Marriott International, Inc. (Marriott). The case was removed to the United States District Court for the Northern District of Georgia based on diversity jurisdiction.Hartford Casualty Insurance Company, which had paid workers’ compensation benefits to Mrs. Hensley, intervened to protect its subrogation lien. The district court applied Indiana tort law and granted summary judgment in favor of the defendants, concluding that they either did not control the hotel premises or lacked actual knowledge of the hazard. The court also dismissed Hartford’s claim, as it depended on the Hensleys' success. The Hensleys appealed the decision.The United States Court of Appeals for the Eleventh Circuit reviewed the case and determined that the district court lost subject matter jurisdiction when Hartford, an indispensable party, intervened, destroying complete diversity. The appellate court vacated the district court’s summary judgment order and remanded the case with instructions to remand it to the State Court of Gwinnett County, Georgia. The main holding was that Hartford’s intervention as a matter of right and its status as an indispensable party required the case to be remanded to state court due to the lack of complete diversity. View "Hensley v. Westin Hotel" on Justia Law

The plaintiff, Daniel Richards, filed a complaint against Union Leader Corporation and Robert Azzi, alleging defamation and invasion of privacy — false light. Richards, a father of two children in the Hanover School District, opposed the district's curricular changes focused on equity and anti-racism. He supported legislation (HB 544) prohibiting New Hampshire schools from teaching that children are inherently racist, sexist, or oppressive. Azzi wrote an op-ed in the Union Leader, labeling Richards and others as disseminators of white supremacist ideology and accusing them of favoring the suppression of rights and history.The Superior Court dismissed Richards' complaint, concluding that the statements in the op-ed were non-actionable opinions rather than defamatory facts. The court found that the statements were hyperbolic and did not imply undisclosed defamatory facts. It also declined to recognize the tort of false light invasion of privacy, ruling that even if such a tort were recognized, Richards' claim would fail because the statements were opinions, not factual assertions.The Supreme Court of New Hampshire affirmed the Superior Court's decision. It agreed that the op-ed's statements were non-actionable opinions and did not imply undisclosed defamatory facts. The court also declined to recognize the tort of false light invasion of privacy, noting that it is largely duplicative of existing defamation law and should be addressed by the legislature if deemed necessary. The court concluded that the trial court did not err in its analysis and upheld the dismissal of Richards' complaint. View "Richards v. Union Leader Corp." on Justia Law

Flor de Maria Mejia was involved in a hit-and-run accident where she struck a bicyclist, William McGill, with her van and fled the scene. The collision caused significant damage to her vehicle and injuries to herself. Shortly after the incident, a parking control officer observed Mejia driving the damaged van and later identified her as the driver. Mejia and her boyfriend subsequently burned the van. Mejia sought medical attention, claiming her boyfriend had assaulted her, but refused a rape examination. Evidence from the burned van and Mejia's social media messages linked her to the crime.The Superior Court of Los Angeles County convicted Mejia of fleeing the scene of an injury accident, resulting in a three-year prison sentence. The jury found her guilty of violating Vehicle Code § 20001, subd. (b)(2), and imposed a restitution obligation of $7,500. Mejia's defense included multiple inconsistent statements to the police and an attempt to shift blame to her boyfriend, Carter, who also testified at trial.The California Court of Appeal, Second Appellate District, reviewed the case. Mejia challenged the identification process, the prosecutor's comments during closing arguments, and the sentencing enhancement for personal infliction of great bodily injury. The court found the identification process was not unduly suggestive, and any assumed Griffin error (prosecutor's comment on Mejia's failure to testify) was harmless beyond a reasonable doubt. The court also addressed the prosecutor's improper comment during rebuttal, concluding that the trial court's immediate and forceful admonition to the jury mitigated any potential prejudice.The court upheld the jury's finding of the sentencing enhancement, stating substantial evidence supported the conclusion that Mejia's failure to render aid exacerbated McGill's injuries. The court affirmed the trial court's restitution order, finding no abuse of discretion. The judgment of the Superior Court was affirmed. View "People v. Mejia" on Justia Law

Wanda Bowling entered into a contract with the Interstate Medical Licensure Compact Commission to manage its information technology functions. When the contract ended, Bowling allegedly withheld login information for three online accounts, leading the Commission to sue for breach of contract. Bowling counterclaimed for libel and misclassification of her employment status. The district court dismissed the misclassification counterclaim and granted summary judgment to the Commission on all other claims.The United States District Court for the District of Colorado dismissed Bowling's counterclaim for misclassification and denied her motion to amend it, citing untimeliness. The court also granted summary judgment to the Commission on its breach of contract claim, concluding that Bowling's login information constituted intellectual property and that she had breached the contract by not certifying the erasure of confidential information. The court awarded the Commission $956.67 in damages. Additionally, the court granted summary judgment on Bowling's libel counterclaim, citing a qualified privilege defense.The United States Court of Appeals for the Tenth Circuit reviewed the case. It affirmed the district court's finding of subject-matter jurisdiction, holding that the Commission had adequately alleged damages exceeding $75,000. However, the appellate court found that the contract was ambiguous regarding whether the login information constituted intellectual property or other materials covered by the contract, and that there was a genuine dispute of material fact regarding the damages. Therefore, it reversed the summary judgment on the breach of contract claim. The court also upheld the district court's denial of Bowling's motion to amend her counterclaim for misclassification, finding no abuse of discretion.On the libel counterclaim, the appellate court agreed that the district court erred in granting summary judgment based on a qualified privilege without giving Bowling notice. However, it affirmed the summary judgment on the grounds that the Commission's statements were substantially true. The case was affirmed in part, reversed in part, and remanded for further proceedings. View "Interstate Medical Licensure Compact Commission v. Bowling" on Justia Law

Catalina Estillado died from injuries sustained in a workplace accident at ABC Polymer Industries, LLC. Her spouse, Crescencio Pablo, filed a wrongful-death claim against her coworkers, Dean Leader and William Durall, alleging their willful conduct caused her death by removing a safety guard from the machine involved. The Jefferson Circuit Court found in favor of Pablo, awarding $3 million in damages. Leader and Durall appealed.The circuit court determined that the machine was originally manufactured with a safety gate interlocked with a limit switch, which was later removed. The court concluded that Durall had effectively "removed" the safety device by not reinstalling it and by training employees to bypass it. The court also found that Durall knew injury was likely from this removal and that the removal was not part of a modification that rendered the safety device unnecessary.The Supreme Court of Alabama reviewed the case. It found that while the machine was originally manufactured with the safety device, there was no evidence that Durall knew the safety gate should be interlocked with a limit switch when he inspected and installed the machine. The court also noted that instructing employees to bypass a safety device does not equate to its removal under § 25-5-11(c)(2), referencing the precedent set in Williams v. Price. Additionally, Durall had left ABC Polymer before Estillado was hired and did not train her.The court concluded that Pablo failed to prove Durall willfully and intentionally removed the safety device. Consequently, the judgment against Durall was reversed, and the case was remanded for further proceedings. The appeal by Leader was dismissed due to his bankruptcy discharge. View "Leader v. Pablo" on Justia Law