Burnett v. United States

CourtDistrict Court, S.D. Ohio
DecidedNovember 13, 2020
Docket1:19-cv-00043
StatusUnknown

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

Bluebook
Burnett v. United States, (S.D. Ohio 2020).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION

KIMBERLY A. BURNETT, : Case No. 19-cv-43 : Plaintiff, : Judge Timothy S. Black : vs. : : THE UNITED STATES OF AMERICA, : et al., : : Defendants. :

ORDER GRANTING: (1) DEFENDANT UNIVERSITY OF CINCINNATI MEDICAL CENTER, LLC’S MOTION FOR JUDGMENT ON THE PLEADINGS (Doc. 25); AND (2) DEFENDANT UC HEALTH, LLC’S MOTION FOR JUDGMENT ON THE PLEADINGS (Doc. 26)

This civil action is before the Court on Defendant University of Cincinnati Medical Center, LLC (“UCMC”)’s motion for judgment on the pleadings (Doc. 25) and the responsive memoranda (Docs. 32, 34), and Defendant UC Health, LLC’s (“UC Health”)’s motion for judgment on the pleadings (Doc. 26)1 and the responsive memoranda (Docs. 31, 35). I. BACKGROUND This case arises out of Plaintiff Kimberly Burnett’s February 20, 2017 surgery at West Chester Hospital, a facility affiliated with UC Health. (Doc. 16 at ¶¶ 1, 7). The

1 UC Health’s motion was initially a partial motion for judgment on the pleadings, however, the claims not addressed in UC Health’s motion for judgment on the pleadings related to vicarious liability for Dr. Phillip Ross, were dismissed by stipulation of the parties. (Doc 46). Accordingly, UC Health seeks to dismiss all remaining claims against in this motion before the Court. surgeons were Dr. Ryan Finnan and Dr. Steven Agabegi, and they were assisted by Dr. Phillip Ross, and Dr. Phillip White, who provided neuromonitoring during the surgery. (Id.). Plaintiff had a prior physician-patient relationship with Dr. Agabegi. (Id. at ¶ 7). Plaintiff alleges that during her surgery, Dr. Finnan, assisted by Dr. Agabegi and Ross, misplaced several iliosacral screws in Plaintiff’s lower spinal canal. (Id.). Plaintiff states that those screws have resulted in permanent damage to certain nerves. (Id.). Plaintiff contends that Dr. White failed to act upon neuromonitoring data during the surgery to prevent intraoperative nerve injury. (Id. at ¶ 9). The Amended Complaint alleges that Defendants UCMC and UC Health are liable

for the alleged conduct of their “credentialed physicians,” including Drs. Agabegi, Finnan, Ross, and White because “[t]here exists ownership, control and/or agency relationships between these defendants as to make them responsible.” (Id. at ¶ 5). Plaintiff also contends that Defendant University of Cincinnati Physicians, Inc., as the alleged employer of the physicians, is vicariously liable, and that the United States

government is vicariously liable for Dr. Finnan, an active member of the Air Force. (Id.). The Amended Complaint contains no allegations that any of the doctors were employed by UCMC, or that Plaintiff ever sought or received medical treatment at UCMC. Moreover, there are no allegations that Drs. Agabegi, Finnan, or White were ever employed by UC Health.2

2 All claims brought by Plaintiff against UC Health based on the vicarious liability of UC Health for the conduct of Dr. Ross have already been dismissed. (Doc. 46). II. STANDARD OF REVIEW The standard of review for a Rule 12(c) motion is the same as for a motion under Rule 12(b)(6) for failure to state a claim upon which relief can be granted. Fritz v. Charter Twp. of Comstock, 592 F.3d 718, 722 (6th Cir. 2010). “For purposes of a motion for judgment on the pleadings, all well-pleaded material allegations of the pleadings of the opposing party must be taken as true, and the motion may be granted only if the moving party is nevertheless clearly entitled to judgment.” Id. (citing JPMorgan Chase Bank v. Winget, 510 F.3d 577, 581 (6th Cir. 2007)). That is, a court should grant a motion for judgment on the pleadings under Rule 12(c) only if “no

material issue of fact exists and the party making the motion is entitled to judgment as a matter of law.” Winget, 510 F.3d at 582 (quoting Paskvan v. City of Cleveland Civil Serv. Comm'n, 946 F.2d 1233, 1235 (6th Cir. 1991)). To show grounds for relief, Federal Rule of Civil Procedure 8(a) requires that the complaint contain a “short and plain statement of the claim showing that the pleader is

entitled to relief.” The Rule “demands more than an unadorned, the-defendant- unlawfully-harmed-me accusation.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007)). Pleadings offering mere “‘labels and conclusions’ or ‘a formulaic recitation of the elements of a cause of action will not do.’” Id. (citing Twombly, 550 U.S. at 555). In fact, in determining a motion to

dismiss, “courts ‘are not bound to accept as true a legal conclusion couched as a factual allegation[.]’” Twombly, 550 U.S. at 555 (citing Papasan v. Allain, 478 U.S. 265 (1986)). Further, “[f]actual allegations must be enough to raise a right to relief above the speculative level[.]” Id. Accordingly, “a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Iqbal, 556 U.S. at 678. A claim is plausible where “plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. Plausibility “is not akin to a ‘probability requirement,’ but it asks for more than a sheer possibility that a defendant has acted unlawfully.” Id. “[W]here the well-pleaded facts do not permit the court to infer more than the mere possibility of misconduct, the

complaint has alleged—but it has not ‘show[n]’—‘that the pleader is entitled to relief,’” and the case shall be dismissed. Id. III. ANALYSIS While the legal issues presented in Defendants UCMC and UC Health’s motions for judgment on the pleadings (Docs. 25, 26) are similar, for clarity’s sake, the Court will

address each motion separately. A. Defendant UCMC’s motion for judgment on the pleadings Defendant UCMC seeks to dismiss all claims against it contained in the Amended Complaint. In the Amended Complaint, Plaintiff alleges that "Plaintiff looked to defendants UCHealth, UCMC, WCH and UCP to provide competent medical care

through the physicians and staff they chose, credentialed and provided.” (Doc. 16 at ¶ 6). Plaintiff’s theory of liability against UCMC is that they are liable for the alleged negligence of “credentialed physicians” who provided medical care to Plaintiff, at an affiliate hospital, West Chester Hospital. However, Plaintiff’s theory of liability against UCMC fails. Under the theory of ostensible agency, in order for a hospital to be held vicariously liable for the negligence of independent medical practitioners practicing in the hospital, a plaintiff must establish that (1) the hospital held “itself out to the public as a provider of medical services; and (2) in the absence of notice or knowledge to the contrary, the patient looks to the hospital, as opposed to the individual practitioner, to provide competent medical care.” Clark v. Southview Hosp. & Family Health Ctr., 68

Ohio St.3d 435 (1994). “If a hospital is to be held vicariously liable for the malpractice of a physician practicing therein, merely granting privileges to the physician is not enough to create a direct agency relationship between the hospital and the physician.” Laderer v. St. Rita's Med. Ctr., 122 Ohio App.

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Related

Papasan v. Allain
478 U.S. 265 (Supreme Court, 1986)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Fritz v. Charter Township of Com-Stock
592 F.3d 718 (Sixth Circuit, 2010)
JPMorgan Chase Bank, N.A. v. Winget
510 F.3d 577 (Sixth Circuit, 2007)
Laderer v. St. Rita's Medical Center
702 N.E.2d 476 (Ohio Court of Appeals, 1997)
Costell v. Toledo Hospital
649 N.E.2d 35 (Ohio Court of Appeals, 1994)
Clark v. Southview Hospital & Family Health Center
68 Ohio St. 3d 435 (Ohio Supreme Court, 1994)

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Bluebook (online)
Burnett v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/burnett-v-united-states-ohsd-2020.