Beck, M.D. v. Fradette

CourtDistrict Court, D. Massachusetts
DecidedMarch 31, 2023
Docket1:22-cv-10389
StatusUnknown

This text of Beck, M.D. v. Fradette (Beck, M.D. v. Fradette) is published on Counsel Stack Legal Research, covering District Court, D. Massachusetts primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Beck, M.D. v. Fradette, (D. Mass. 2023).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS

ADAM P. BECK, M.D., et al., * * Plaintiffs, * * v. * Civil Action No. 1: 22-cv-10389-IT * H. BRIGGS BEDIGIAN and GILMAN & * BEDIGIAN, LLC, * * Defendants.

MEMORANDUM & ORDER

March 31, 2023 TALWANI, D.J. Pending before the court is Plaintiffs Adam Beck, Adam P. Beck, M.D., P.C. (“Beck P.C.”), and Bethany Carey’s Motion for Reconsideration (“Motion”) [Doc. No. 37] of Memorandum and Order [Doc. No. 32] dismissing Plaintiffs’ claims against Defendants H. Briggs Bedigian (“Bedigian”) and Gilman & Bedigian, LLC (“Gilman & Bedigian”) for lack of personal jurisdiction. For the reasons set forth below, Plaintiffs’ Motion [Doc. No. 37] is DENIED. I. Background A. The Original Record Before the Court and the Court’s Findings The court’s Memorandum and Order [Doc. No. 32] discussed in detail the factual background and the evidentiary record as to personal jurisdiction then before the court and that background is incorporated here by reference. With respect to general jurisdiction, relying upon Defendant Bedigian’s sworn affidavit, the court found that Defendants “are not engaged in continuous and systematic activity, unrelated to this suit, such that general jurisdiction exists.” Mem. & Order 10 [Doc. No. 32]. As to specific jurisdiction, the court noted that there is a “natural blurring” of the first and second prongs of the analysis—relatedness and purposeful availment—in cases where “the alleged contacts are less tangible than physical presence” and the court must determine “the extent to which the defendant directed an out-of-state activity at the forum state[.]” Id. (quoting Phillips Exeter Acad. v. Howard Phillips Fund, 196 F.3d 284, 289 (1st Cir. 1999)). The court

rejected “Plaintiffs’ reliance on Calder v. Jones, 465 U.S. 783 (1984), where the Supreme Court found that a newspaper had purposefully availed itself of California because it circulated 60,000 copies in that state and published a libelous story about a celebrity who lived there[.]” Id. at 11. In doing so, the court distinguished Calder from the instant case where Plaintiffs contended that Defendants relied on Beck’s name and the Knox medical malpractice case in the blog post to attract business in Massachusetts but proffered no evidence to support such an allegation. Id. The court also found that Plaintiffs had not shown Defendants purposefully availed themselves of Massachusetts where the only fact in the record in support of that claim was that Defendants’ website is accessible in Massachusetts. Id. at 12. Accordingly, the court held that specific jurisdiction did not exist over Defendants in Massachusetts. Id.1

The court further held that personal jurisdiction as to Defendants did not exist under subsections (a), (b), (c) and (d) of the Massachusetts long-arm statute, M.G.L. c. 223A, § 3. Id. at 4–9. The court found § 3(a) inapplicable where Plaintiffs had not pointed to a single transaction in Massachusetts conducted by Defendants. Id. at 5. Similarly, the court found § 3(b) inapplicable where absent Defendants’ advertisement boasting that they handle birth injury cases nationwide in cooperation with local counsel, Plaintiffs had not proffered any evidence to rebut

1 The court did not reach the reasonableness prong of the specific jurisdiction analysis. Defendants’ sworn statement that they have not provided such services in Massachusetts. Id. at 6. With respect to § 3(c), the court found inapposite the line of cases holding that defamatory statements purposefully directed towards a Massachusetts resident constitute an in- forum act for purposes of § 3(c) where Plaintiffs had not proffered any evidence absent

conclusory allegations that Defendants specifically targeted Beck, knew he lived in Massachusetts at the time the blog post was published, or intended to harm his reputation in Massachusetts. Id. at 8. The court found that § 3(d) did not apply where Plaintiffs had not made any supported allegations that Defendants “regularly” or “persistently” solicit business or engage in conduct in Massachusetts and Defendants provided a sworn affidavit that they have never conducted marketing or advertising campaigns in Massachusetts and have never sent mailings to Massachusetts. Id. B. Further Evidentiary Record Regarding Personal Jurisdiction Provided in Connection with the Pending Motion On December 15, 2020, when the blog at issue in this litigation was posted on Gilman & Bedigian’s website, Bedigian did not know that Beck lived in Massachusetts. Supp. Aff. of H. Briggs Bedigian (“Bedigian Supp. Aff.”) ¶ 11 [Doc. No. 39-1]. Gilman & Bedigian’s website includes web pages titled “Massachusetts Medical Malpractice Laws” and “Massachusetts Birth Injury” (collectively “Massachusetts Web Pages”).

Id. at ¶ 2. The Massachusetts Birth Injury web page inter alia provides (i) details about the types, symptoms, and causes of birth injuries; (ii) the compensation available for victims, limitations on damages, and statute of limitations for birth injuries in Massachusetts; and (iii) that lawyers at Gilman & Bedigian can assist with birth injury claims in Massachusetts. See Adam. P. Beck Decl. in Supp. of Mot. for Recons. (“Beck Decl.”) ¶ 4 [Doc. No. 38]. Specifically, the web page provides: In Massachusetts, a birth injury is a legal term for what happens when a newborn baby or an unborn fetus is hurt because a doctor or other healthcare professional committed medical malpractice. The consequences of a birth injury are often life long, and can even be fatal.

Recovering compensation is essential if the victim and his or her family want to live as close to a full life as possible. The birth injury lawyers at Gilman & Bedigian can help make that happen for victims in Massachusetts.

Ex. 1, Massachusetts Birth Injury, Gilman & Bedigian’s website 10 [Doc. No. 38-1]. The web page ends with the following: BIRTH INJURY LAWYERS AT GILMAN & BEDIGIAN SERVE MASSACHUSETTS If you or your child has been born with a birth injury and suspect that it was caused by a doctor’s malpractice, reach out to the birth injury lawyers at Gilman & Bedigian by contacting us online. Id. at 14. The Massachusetts Medical Malpractice Laws web page includes, inter alia, information about who may bring a claim for medical malpractice against whom, how long one has to bring a claim, types of permissible damages awarded, expert witnesses, settlements, how to find legal representation, and notable decisions from Massachusetts. Ex. 1, Massachusetts Medical Malpractice Laws, Gilman & Bedigian’s website 2–9 [Doc. No. 38-1]. This web page ends with the following: LET US HELP If someone you are close to has been seriously injured or worse, you are naturally devastated not only by what has happened, but by the effect that the injury or loss has had on you and your family. At a time when you’re vulnerable, traumatized and emotionally exhausted, you need a team that will support you through the often complex process that lies ahead. Id. at 9. Gilman & Bedigian’s website contains similar Medical Malpractice Law and Birth Injury web pages for the other forty-nine states. Bedigian Supp. Aff. ¶ 4 [Doc. No. 44-3]. As of August 2022, when the Defendants filed their opposition to the motion for reconsideration, the Defendants had not provided any services to Massachusetts residents and have not engaged with local counsel to provide such services, nor had plans to do so. Id. at ¶ 13.

Gilman & Bedigian’s website has an interactive chat feature to contact a Bedigian representative about a potential malpractice case. Beck Decl. ¶ 6 [Doc. No. 38].

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Beck, M.D. v. Fradette, Counsel Stack Legal Research, https://law.counselstack.com/opinion/beck-md-v-fradette-mad-2023.