Crupi v. Heights of Summerlin, LLC

CourtDistrict Court, D. Nevada
DecidedFebruary 17, 2022
Docket2:21-cv-00954
StatusUnknown

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

Bluebook
Crupi v. Heights of Summerlin, LLC, (D. Nev. 2022).

Opinion

1 UNITED STATES DISTRICT COURT

2 DISTRICT OF NEVADA

3 RACHELLE CRUPI, individually, and as ) 4 Special Administrator, Personal Representative, ) and heir to the Estate of ALETHA PORCARO, ) Case No.: 2:21-cv-00954-GMN-DJA 5 deceased, ) ) ORDER 6 Plaintiff, ) 7 vs. ) ) 8 The Heights of Summerlin, LLC, et al., ) ) 9 Defendants. ) 10 11 Pending before the Court is Plaintiff Rachelle Crupi’s (“Plaintiff’s”) Motion to Remand, 12 (ECF No. 18). Defendants The Heights of Summerlin, LLC, Summit Care, LLC, Genesis 13 Healthcare, Inc., Latoya Davis, and Andrew Reese (collectively, “Defendants”) filed a 14 Response, (ECF No. 34), and Plaintiff filed a Reply, (ECF No. 42). 15 Also pending before the Court are Defendants’ Motions to Dismiss, (ECF Nos. 5, 6, 10, 16 and 31). Plaintiff filed Responses, (ECF Nos. 16, 19, 28, and 40), and Defendants filed 17 Replies, (ECF Nos. 35, 36, 37, and 44). 18 For the reasons discussed below, the Court GRANTS Plaintiff’s Motion to Remand and 19 DENIES as moot Defendants’ Motions to Dismiss. 20 I. BACKGROUND 21 This case arises out of the death of Aletha Porcaro from COVID-19 after her inpatient 22 stay at The Heights of Summerlin’s skilled nursing facility, (“The Heights Facility”), which 23 primarily treats elderly individuals. (See generally Complaint, ECF No. 1-2). On February 15, 24 2020, Ms. Porcaro arrived at The Heights Facility for post-acute rehabilitation following 25 surgery to repair a fractured femur. (Compl. ¶ 33). On April 13, 2020, The Heights Facility 1 discharged Ms. Porcaro and transitioned her to a senior-living apartment complex, where she 2 began complaining of pain and discomfort. (Id. ¶¶ 121, 127). On April 14, 2020, Ms. Porcaro 3 started exhibiting COVID-19 symptoms, and she was transported to Summerlin Hospital for a 4 COVID-19 test, which came back positive. (Id. ¶¶ 128–129). On April 21, 2020, Ms. Porcaro 5 was pronounced dead, with COVID-19 listed as the cause of death on her death certificate. (Id. 6 ¶ 130). 7 Plaintiff, Rachelle Crupi, is Ms. Porcaro’s daughter, and she filed this case as special 8 administrator, personal representative, and heir to her mother’s estate, alleging that Ms. Porcaro 9 contracted COVID-19 during her stay at The Heights Facility. (Id. ¶ 1). Plaintiff claims that 10 Defendants negligently failed to take measures to protect Ms. Porcaro, and the other elderly 11 residents at The Heights Facility, from COVID-19 in violation of their duties under 42 C.F.R. § 12 483 and NAC § 449. (Id. ¶¶ 57–71). Specifically, Plaintiff claims that The Heights Facility 13 neglected to implement a litany of procedures to reduce the transmission of infectious disease, 14 such as proper infection control practices; policies for the use and disposition of personal 15 protective equipment (“PPE”); screening visitors, employees and new residents for signs and 16 symptoms of COVID-19; policies for quarantining and social distancing; displaying 17 appropriate COVID-19 signage; disinfecting of surfaces and equipment; and reporting COVID- 18 19 cases and deaths. (Id. ¶¶ 41, 72–116). Plaintiff further alleges that reports from the United 19 States Department of Health and Human Services (“HHS”), Centers for Medicare and Medicaid 20 Services and various state agencies revealed deficiencies in The Heights Facility’s COVID-19 21 response. (Id. ¶¶ 36–56). 22 Plaintiff originally filed her Complaint in the Eighth Judicial District Court of Clark

23 County, Nevada, alleging eight causes of action under Nevada state law: (1) 24 Negligence/Negligence per se; (2) Negligent Hiring, Training, Retention, and/or Supervision; 25 (3) Abuse and Neglect of an Older/Vulnerable Person; (4) Breach of Contract; (5) Negligent 1 Misrepresentation; (6) Fraud/Intentional Misrepresentation; (7) Wrongful Death; and (8) 2 Professional Negligence. (Id. ¶¶ 132–245). Defendants then removed the case to the United 3 States District Court for the District of Nevada. (Pet. Removal 2:1–4, ECF No. 1). Defendants 4 allege that this Court has subject matter jurisdiction because Plaintiff’s claims are completely 5 preempted by the Public Readiness and Emergency Preparedness Act (“PREP Act”), 42 U.S.C. 6 § 247d-6d(d). (Id. 3:10–15). Plaintiff now moves to remand the case back to state court. (See 7 generally, Mot. Remand, ECF No. 18). 8 II. LEGAL STANDARD 9 Federal courts are courts of limited jurisdiction, possessing only those powers granted by 10 the Constitution and by statute. See United States v. Marks, 530 F.3d 799, 810 (9th Cir. 2008). 11 “If at any time before final judgment it appears that the district court lacks subject matter 12 jurisdiction, the case shall be remanded.” 28 U.S.C. § 1447(c). Generally, district courts have 13 subject matter jurisdiction over civil actions in which: (1) the claims arise under federal law; or 14 (2) where no plaintiff is a citizen of the same state as a defendant and the amount in 15 controversy exceeds $75,000.00. See 28 U.S.C. §§ 1331, 1332(a). 16 A civil action brought in state court may be removed to a federal district court if the 17 district court has original jurisdiction over the matter. 28 U.S.C. § 1441(a). The defendant 18 asserting the removal must prove it is proper, and there is a strong presumption against removal 19 jurisdiction. Gaus v. Miles, Inc., 980 F.2d 564, 566 (9th Cir. 1992). “Federal jurisdiction must 20 be rejected if there is any doubt as to the right of removal in the first instance.” Id. (quoting 21 Libhart v. Santa Monica Dairy Co., 592 F.2d 1062, 1064 (9th Cir. 1979)). 22 III. DISCUSSION

23 Defendants argue that Plaintiff’s state law claims are completely preempted by the 24 PREP Act, and thus, the Court has federal question subject matter jurisdiction1 over this case. 25 1 Defendants never allege that this Court has diversity subject matter jurisdiction. 1 (Resp. 3:22–27, ECF No. 34). The PREP Act provides: “a covered person shall be immune 2 from suit and liability under Federal and State law with respect to all claims for loss caused by, 3 arising out of, relating to, or resulting from the administration to or the use by an individual of a 4 covered counter measure if a declaration . . . has been issued with respect to such a 5 countermeasure.” 42 U.S.C. § 247d-6d(a)(1). In light of the COVID-19 pandemic, the 6 Secretary of Health and Human Services declared a public health emergency and extended the 7 PREP Act’s liability immunity to medical countermeasures employed against COVID-19. See 8 85 Fed. Reg. 15198 (March 17, 2020). Defendants allege both that they are “covered 9 individuals” under the PREP Act and that implementation of an infectious disease program 10 necessarily relies on the use of “covered countermeasures,” such as COVID-19 test kits and 11 N95 respirator masks. (Resp. 3:16–21, 6:3–13). As such, Defendants argue that the PREP Act 12 immunizes them from suit, Plaintiff’s state law claims are completely preempted, and 13 jurisdiction in this Court is proper. (Id. 3:22–27).

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