BAUTISTA v. TEMPLE UNIVERSITY HOSPITAL, INC.

CourtDistrict Court, E.D. Pennsylvania
DecidedAugust 28, 2025
Docket2:25-cv-03101
StatusUnknown

This text of BAUTISTA v. TEMPLE UNIVERSITY HOSPITAL, INC. (BAUTISTA v. TEMPLE UNIVERSITY HOSPITAL, INC.) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
BAUTISTA v. TEMPLE UNIVERSITY HOSPITAL, INC., (E.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

CAROLINA NINA BAUTISTA, CIVIL ACTION Individually and as Parent and Natural Guardian of F.M., a Minor, Plaintiff,

v.

TEMPLE UNIVERSITY HOSPITAL, INC., and TEMPLE UNIVERSITY NO. 25-3101 HOSPIAL SYSTEM INC., Defendants and Third-Party Plaintiffs,

CLINTON A. TURNER, M.D., Third-Party Defendant.

MEMORANDUM OPINION Plaintiff Carolina Nina Bautista (“Bautista”) gave birth to her son (“F.M.”) at Temple University Hospital. He was born premature—she was 28 weeks pregnant when she began experiencing intermittent contractions and went to the hospital. Tests showed an abnormal fetal heart rate and other signs of pre-term labor, but critical medical intervention was delayed for hours. The delay, according to a Complaint she filed against Defendants Temple University Hospital, Inc. and Temple University Health System, Inc. (together, the “Temple Defendants”), meant that F.M. was born with catastrophic brain injuries that will impair him for the rest of his life. Bautista, proceeding individually and as the parent and natural guardian to F.M., sued the Temple Defendants in state court for professional negligence, corporate negligence, and negligent infliction of emotional distress (“NIED”). The Temple Defendants filed a Joinder Complaint seeking indemnity and contribution against Third-Party Defendant Clinton A. Turner (“Turner”), the attending obstetrician who allegedly was responsible for Bautista’s care during her time at Temple University Hospital. The United States of America (the “United States” or the “Government”) intervened and

removed the matter to federal court, asserting that because Turner was employed by Delaware Valley Community Health, Inc. (“DVCH”), a covered employer under a federal public health service program, any claim against him arising from his care of Bautista belongs in federal court. The Government now moves, pursuant to Federal Rule of Civil Procedure 21,1 to dismiss Turner from the above-captioned action and substitute itself in his place as the sole Third-Party Defendant. Separately, Bautista moves to sever and remand her claims against the Temple Defendants from the Temple Defendants’ third-party claims. For the reasons that follow, the Government’s Motion shall be granted and Bautista’s Motion shall be denied. I. BACKGROUND On the morning of August 16, 2023, Bautista, then 20 years-old and 28 weeks into her first pregnancy, went to the emergency room at Temple University Hospital in Philadelphia after

experiencing contractions which were approximately ten minutes apart. Nurses performed an initial exam and connected her to a fetal heart rate monitor. Over the next several hours, she continued to have contractions and demonstrated signs of pre-term labor. Meanwhile, her fetal heart tracings “reflected concerning findings, including fetal tachycardia and decelerations.” Despite those symptoms, the nurses attending to Bautista did not promptly call an

1 In addition to Rule 21, the Government also purports to bring its Motion for Substitution pursuant to Rule 12(b)(1), which provides that a claim may be dismissed for “lack of subject matter jurisdiction.” See Fed. R. Civ. P. 12(b)(1). However, aside from a passing argument that “the Court lacks subject-matter jurisdiction to adjudicate Temple’s third-party claims as asserted against [Turner],” the Government does not explain why dismissal is appropriate under that Rule. For the reasons set forth more fulsomely below, Rule 21 provides complete and adequate relief in deciding the Government’s Motion for Substitution, so the Court need not address the grounds for dismissal, if any, under Rule 12(b)(1). obstetrician or maternal fetal medicine specialist to evaluate her. Only after an approximately three hour wait in the emergency room was she finally admitted and transferred to the labor and delivery floor of the hospital. About an hour and a half later, she was seen by two resident physicians and given an initial course of steroids and antibiotics. She was also examined by an

attending maternal fetal medicine physician. Shortly thereafter, however, a nurse documented that Bautista’s “membranes spontaneously ruptured.” Notwithstanding that observation, roughly three hours passed before a resident physician “returned to [her] bedside to evaluate her cervix.” During that evaluation, the physician began to suspect that Bautista was suffering from “chorioamnionitis”—a bacterial infection of the fetal membranes and amniotic fluid—and, as a result, recommended immediate delivery. At 4:14pm—approximately nine hours after arriving at Temple University Hospital— Bautista delivered F.M., who suffered “catastrophic brain injuries” at birth. Due to the “prolonged intrauterine hypoxia,” he was “profoundly acidotic” upon delivery, and was eventually diagnosed with hydrocephalus. Bautista avers that F.M.’s neurological injuries are

permanent and “will disable him in every aspect of his life, for the rest of his life.” She maintains that “[h]ad F.M. been timely delivered, as the standard of care required, he would not have suffered the brain injuries he did, and he would not be in the neurologically devastated condition []he is today.” Further, as described in her Complaint, the entire ordeal put Bautista herself through “significant mental anguish” and “severe emotional distress.” II. MOTION TO SUBSTITUTE A. Legal Standards i. Rule 21 Turning first to the Government’s Motion to Substitute: Rule 21 “empowers courts to police the litigation’s cast of characters.” Avenatti v. Fox News Network LLC, 41 F.4th 125, 130 (3d Cir. 2022) (citations omitted). It provides: “Misjoinder of parties is not a ground for dismissing an action. On motion or on its own, the court may at any time, on just terms, add or drop a party. The court may also sever any claim against a party.” Fed. R. Civ. P. 21. Rule 21 can be exercised, among other reasons, to “preserve subject matter jurisdiction.” Avenatti, 41

F.4th at 130 (citations omitted). “Significantly, because Rule 21 does not contain explicit standards governing the propriety of joinder or severance—that is, what constitutes ‘just terms’—courts sometimes must incorporate standards to be found elsewhere in exercising their Rule 21 discretion.” Id. at 131 (citations and internal quotation marks omitted). That said, Rule 21 authority, while discretionary, is not unlimited. Id. For instance, a district court “cannot drop indispensable parties, and it must assure itself that its actions will not prejudice any party.” Id. (citations omitted). ii. Federally Supported Health Centers Assistance Act Here, the Government’s Rule 21 argument is that Turner was, at all relevant times, employed by DVCH—an entity the Government certifies has been “deemed” a federal employer under the Federally Supported Health Centers Assistance Act (the “FSHCAA”), 42 U.S.C. §

233—and thus, pursuant to that statute, “just terms” exist to substitute the United States in his stead as the proper party to defend against the Temple Defendants’ third-party indemnity and contribution claims against him. To understand the application of the FSHCAA, a brief foray into the relevant provisions of the Public Health Service Act (the “PHSA”), 42 U.S.C. § 233(a), and the Federal Tort Claims Act (the “FTCA”), see 28 U.S.C.

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