Christopher Fields v. HCA Healthcare, et al.

District Court, N.D. Texas·Decided August 11, 2026·No. 3:26-cv-00354·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION CHRISTOPHER FIELDS, § § Plaintiff, § § VS. § Civil Action No. 3:26-CV-0354-D § HCA HEALTHCARE, et al., § § Defendants. § MEMORANDUM OPINION AND ORDER In this action, plaintiff Christopher Fields (“Fields”), who is Black, alleges claims for discrimination under the Patient Protection and Affordable Care Act, (“ACA”),42 U.S.C. § 18116, and 42 U.S.C. § 1981. Defendants move under Fed. R. Civ. P. 12(b)(6) to dismiss Fields’s claims. For the reasons that follow, the court grants defendants’ motion in part, denies it in part, and grants Fields leave to replead.1 I Fields was injured in an automobile accident on February 10, 2022. John Inks (“Inks”) and Trinity Line (“Line”), who are both White, were also injured in the accident. Fields, Inks, and Line were transported to, and arrived at, defendants’ hospital around the 1Defendants filed on May 19, 2026 a motion to dismiss Fields’s original complaint. Because the original complaint has been superseded by Fields’s first amended original complaint, the court denies the motion to dismiss the original complaint as moot. See, e.g., Stredwick v. Dall. Margarita Soc’y, Inc., 2012 WL 12893430, at *1 (N.D. Tex. June 27, 2012) (Furgeson, J.) (collecting cases) (“The filing of an amended complaint generally renders pending motions moot.”). same time. About one hour after Fields arrived, the hospital triaged him as a “low-acuity, semi- urgent patient.” Am. Compl. (ECF No. 11) ¶ 17 (internal quotation marks omitted). Fields

alleges that, after the hospital processed him, he was placed in a wheelchair in the waiting room, subjected to delayed pain management, given an incomplete diagnostic work-up, and nearly discharged with an undiagnosed fracture. According to Fields, his treatment at the hospital improved after his mother arrived and a nursing supervisor became involved.

Fields asserts that Inks and Line received superior care: that the hospital placed Inks and Line in treatment rooms, placed Line on a trauma protocol and provided her intravenous medications, and treated Inks and Line before it completed Fields’s diagnostic work-up.2 Fields does not, however, plead further factual details regarding Inks’s and Line’s injuries, triage, or other aspects of their care.

On February 10, 2026 Fields filed this lawsuit, alleging claims under the ACA and § 1981. Defendants move under Rule 12(b)(6) to dismiss Fields’s amended complaint. Fields has not responded to the motion, which the court is now deciding on the briefs, without oral argument.

2Fields also alleges that the hospital discharged Inks and Line before it completed his diagnostic work-up. But Fields also alleges that his mother—who arrived at the hospital after his diagnostic work-up—personally observed Inks and Line in treatment rooms. -2- II “In deciding a Rule 12(b)(6) motion to dismiss, the court evaluates the sufficiency of [plaintiff’s] amended complaint by ‘accept[ing] all well-pleaded facts as true, viewing them

in the light most favorable to the plaintiff.’” Bramlett v. Med. Protective Co. of Fort Wayne, Ind., 855 F.Supp.2d 615, 618 (N.D. Tex. 2012) (Fitzwater, C.J.) (second alteration in original) (internal quotation marks omitted) (quoting In re Katrina Canal Breaches Litig., 495 F.3d at 205). To survive a Rule 12(b)(6) motion to dismiss, the plaintiff must plead

“enough facts to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). “The plausibility standard is not akin to a ‘probability requirement,’ but it asks for more than

a sheer possibility that a defendant has acted unlawfully.” Id.; see also Twombly, 550 U.S. at 555 (“Factual allegations must be enough to raise a right to relief above the speculative level[.]”). “[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 ‘shown’—‘that the pleader is entitled to relief.’” Iqbal, 556 U.S. at 679 (alteration omitted) (quoting Rule

8(a)(2)). “Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Id. at 678.

-3- III Defendants contend that the court should construe Fields’s federal-law claims as health care liability claims under Texas state law. To support this contention, defendants rely

on cases that have held that a plaintiff cannot, through artful pleading, avoid certain requirements codified in Chapter 74 of the Texas Civil Practice and Remedies Code by recasting health care liability claims as other state-law causes of action. See, e.g., Loaisiga v. Cerda, 379 S.W.3d 248, 252, 255 (Tex. 2012). But this caselaw is inapposite because

Fields has pleaded federal-law claims. Thus the court declines to construe Fields’s federal- law claims as health care liability claims. IV The court next considers defendants’ contention that Fields’s ACA claim is time barred.

A Section 1658(a) provides a default statute of limitations for federal causes of action. See 28 U.S.C. § 1658(a). Unless federal law provides otherwise, a civil action “arising under” a federal statute enacted after December 1, 1990 is subject to a four-year statute of limitations. Id. In enacting § 1658, Congress sought to “alleviat[e] the uncertainty inherent

in the practice of borrowing state statutes of limitations.” Jones v. R.R. Donnelley & Sons Co., 541 U.S. 369, 382 (2004). The ACA’s nondiscrimination provision relies on pre-existing anti-discrimination statutes. 42 U.S.C. § 18116(a). Relevant here, § 18116(a) adopts the prohibited grounds for -4- discrimination and the enforcement mechanisms of Title VI of the Civil Rights Act of 1964 (“Title VI”), 42 U.S.C. 2000d et seq. Id. Section 18116 “does not, however, provide a specific statute of limitations.” Palacios v. MedStar Health, Inc., 298 F.Supp.3d 87, 91

(D.D.C. 2018) (citing 42 U.S.C. § 18116(a)). B Fields filed this lawsuit on February 10, 2026, and the alleged discrimination occurred on February 10, 2022. He maintains that § 1658’s four-year statute of limitations applies

because his ACA claim arises under an act of Congress enacted after December 1, 1990. Defendants respond that Texas’ two-year statute of limitations for personal injury suits applies because § 18116(a) incorporates Title VI’s borrowed statute of limitations.3 C The court holds that § 1658’s four-year statute of limitations applies to Fields’s ACA

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Christopher Fields v. HCA Healthcare, et al., (N.D. Tex. 2026).

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