Bradley T. Kendrick and Hendrick Medical Center v. Maria Garcia, as Administratrix of the Estate of Edward A. Martinez

CourtCourt of Appeals of Texas
DecidedAugust 18, 2005
Docket11-04-00192-CV
StatusPublished

This text of Bradley T. Kendrick and Hendrick Medical Center v. Maria Garcia, as Administratrix of the Estate of Edward A. Martinez (Bradley T. Kendrick and Hendrick Medical Center v. Maria Garcia, as Administratrix of the Estate of Edward A. Martinez) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Bradley T. Kendrick and Hendrick Medical Center v. Maria Garcia, as Administratrix of the Estate of Edward A. Martinez, (Tex. Ct. App. 2005).

Opinion

                                                             11th Court of Appeals

                                                                  Eastland, Texas

                                                                        Opinion

Bradley T. Kendrick and Hendrick Medical Center

Appellants

Vs.                   No.  11-04-00192-CV -- Appeal from Taylor County

Maria Garcia, as Administratrix of the Estate of Edward A. Martinez

Appellee

This appeal involves some of the recent changes made to the expert report requirements for health care liability claims.  See TEX. CIV. PRAC. & REM. CODE ANN. ' 74.351 (Vernon 2005).  Appellee, Maria Garcia, as Administratrix of the Estate of Edward A. Martinez, filed a medical malpractice claim against appellants, Dr. Bradley T. Kendrick (Dr. Kendrick) and Hendrick Medical Center (HMC), on January 21, 2004.  Since the claim was filed after September 1, 2003, the provisions of Section 74.351 apply to appellee=s lawsuit.  Section 74.351(a) requires a claimant in a health care liability claim to  Aserve on each party or the party=s attorney one or more expert reports@ not later than the 120th day after the date the claim is filed.  (Emphasis added)  Appellants filed motions on May 25, 2004, and June 4, 2004, seeking the dismissal of appellee=s claims on the basis that she had not served them with expert reports within 120 days of filing suit as required by Section 74.351(a).  See Section 74.351(b).  Appellants challenge the trial court=s denial of their motions to dismiss in this interlocutory appeal.  See TEX. CIV. PRAC. & REM. CODE ANN. ' 51.014(a)(9) (Vernon Supp. 2004 - 2005).  We reverse and render an order of dismissal.

                                                                 Underlying Facts


Appellee filed the reports and curriculum vitaes of two experts with the district clerk=s office on March 26, 2004, and April 8, 2004.[1]  Appellee did not serve appellants with a copy of these documents at the time of filing as required by TEX.R.CIV.P. 21.  After appellants filed their motions to dismiss, appellee=s counsel filed a Acertificate of service@ for the documents wherein counsel alleged that the two expert reports and curriculum vitaes were served on appellants on April 12, 2004, Ain accordance with the Texas Rules of Civil Procedure, Rule 21a and in compliance with Tex. Civ. Prac. Rem. Code ' 74.351.@  See TEX.R.CIV.P. 21a. 

Appellee=s counsel detailed the manner in which she provided appellants with a copy of the reports on April 12, 2004, in an affidavit attached to appellee=s reply to the motions to dismiss.  With respect to Dr. Kendrick, counsel alleged that she placed a copy of the reports in a box located in the district clerk=s office that is assigned to the law firm that represented Dr. Kendrick at trial.  Counsel also stated that she mailed a copy of the reports to HMC=s attorney of record via first class U.S. mail.  Appellants= attorneys of record denied receiving the documents at any time prior to the expiration of the 120-day deadline.  They contend that they first received a copy of the documents when appellee=s counsel faxed a copy to them on May 27, 2004.[2]

After conducting a brief hearing on the motions to dismiss, the trial court issued a letter ruling announcing its decision to deny the motions.  The letter detailed the reasons why the trial court denied the motions.  The trial court stated in the letter that appellee Aattempted in good faith to notify [appellants]@ about the expert reports.  With respect to HMC,  the trial court stated that appellee complied with Section 74.351.  The trial court noted in this regard that HMC did not rebut the allegation that the documents were mailed to its attorney of record on April 12, 2004.  With respect to Dr. Kendrick, the trial court stated as follows:

[T]he Court finds that [appellee] has made a good faith effort to comply with [Section] 74.351 by filing said report and vitae on April 8, 2004, and by placing said report and vitae in the attorney=s box located in the District Clerk=s office.  While [appellee=s] efforts may not be technically correct or advisable, I believe that the spirit of [Section] 74.351 has been complied with.  The Court does not find that placing an expert report and vitae in a box located in the Clerk=s office is service under [TEX.R.CIV.P.] 21a.  Therefore, [Dr. Kendrick=s] Motion to Dismiss for failing to comply with [Section] 74.351 is denied.

After directing appellee=s counsel to prepare an order denying the motions to dismiss, the letter concluded with the following sentence:  AThis letter will be in the file should any higher authority wish to review the Court=s reasoning.@ 


                                              The Effect of the Trial Court=s Letter Ruling

As a preliminary matter, we must determine the effect, if any, of the trial court=s letter ruling.  Appellants have essentially treated the letter as the trial court=s findings of fact and conclusions of law.  This treatment of the letter is not unreasonable given the trial court=s statement of its intent for appellate courts to rely on the letter.  However, there is some authority which holds that a letter ruling issued prior to the entry of the trial court=s order is not competent evidence of the basis for the trial court=s judgment.  Cherokee Water Company v. Gregg County Appraisal District,

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Bradley T. Kendrick and Hendrick Medical Center v. Maria Garcia, as Administratrix of the Estate of Edward A. Martinez, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bradley-t-kendrick-and-hendrick-medical-center-v-m-texapp-2005.