Elaine Neidig v. Valley Health System (Justice Armstead, dissenting)

CourtWest Virginia Supreme Court
DecidedJune 10, 2025
Docket24-27
StatusSeparate

This text of Elaine Neidig v. Valley Health System (Justice Armstead, dissenting) (Elaine Neidig v. Valley Health System (Justice Armstead, dissenting)) is published on Counsel Stack Legal Research, covering West Virginia Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Elaine Neidig v. Valley Health System (Justice Armstead, dissenting), (W. Va. 2025).

Opinion

FILED No. 24-27, Elaine Neidig, individually and on behalf of all others similarly situated v. Valley Health System June 10, 2025 released at 3:00 p.m. EDYTHE NASH GAISER, CLERK ARMSTEAD, Justice, dissenting: SUPREME COURT OF APPEALS OF WEST VIRGINIA The West Virginia Medical Professional Liability Act, West Virginia Code

§§ 55-7B-1 – 12 (“MPLA”), is, by design, a broad and encompassing measure designed to

govern civil actions arising from the provision, or failure to provide, adequate health care

services to our citizens. The majority’s opinion in this case improperly limits the scope

and coverage of the MPLA. Accordingly, I dissent from the majority’s answer to the

certified question from the United States Court of Appeals for the Fourth Circuit because

I believe that, by following the majority’s opinion, a plaintiff may avoid application of the

MPLA by utilizing artful pleading, a result that has previously been soundly rejected by

this Court. Ms. Neidig creatively couches her claims as unfair and deceptive acts and

practices pursuant to the West Virginia Consumer Credit Protection Act (W. Va. Code §§

46A-6-101 – 110), breach of contract, and unjust enrichment. What the majority opinion

fails to recognize is that the petitioner’s unfair and deceptive acts and practices, breach of

contract, and unjust enrichment claims are all based upon a deviation from the standard of

care for a mammogram. In other words, Ms. Nedig will, essentially, have to establish a

medical negligence claim in order to prevail. The majority incorrectly centers its attention,

not upon the nature of the petitioner’s factual allegations, but upon her characterization of

the type of damages she seeks. Additionally, the petitioner’s breach of contract claim is an

anchor claim that falls within the terms of the MPLA. As such, I firmly believe that the 1 United States District Court for the Northern District of West Virginia was correct in its

decision that the petitioner’s claims fall squarely within the scope of the MPLA. Because

the MPLA applies to this case and the allegations in the petitioner’s complaint fall outside

the one-year statute of limitations governing the MPLA, the petitioner’s complaint should

be dismissed. Accordingly, I would answer the Fourth Circuit’s original certified question

in the affirmative.

As noted by both the majority and Justice Walker’s concurrence, for the

MPLA to apply, a cause of action must fall within the Act’s definitions of “medical

professional liability” and “health care.” Under the Act, “medical professional liability” is

defined broadly to mean:

[A]ny liability for damages resulting from the death or injury of a person for any tort or breach of contract based on health care services rendered, or which should have been rendered, by a health care provider or health care facility to a patient. It also means other claims that may be contemporaneous to or related to the alleged tort or breach of contract or otherwise provided, all in the context of rendering health care services.

Id. § 55-7B-2(i) (emphasis added). The Legislature has defined the term “injury” to mean

“injury or death to a patient arising or resulting from the rendering of or failure to render

health care.” Id. § 55-7B-2(h). Finally, “health care,” is defined, in relevant part, as:

Any act, service or treatment performed or furnished, or which should have been performed or furnished, by any health care provider or person supervised by or acting under the direction of a health care provider or licensed professional for, 2 to, or on behalf of a patient during the patient’s medical care, treatment or confinement, including, but not limited to, staffing, medical transport, custodial care, or basic care, infection control, positioning, hydration, nutrition, and similar patient services.

Id. § 55-7B-2(e)(2). We have stated that a health care claim is the necessary anchor from

which MPLA application flows:

The “health care” claim is the “anchor;” it gets you in the door of MPLA application to allow for inclusion of claims that are “contemporaneous to or related to” that claim, but still must be in the overall context of rendering health care services. It is not a broad stroke application that because a claim is contemporaneous to or related to health care that it falls under the MPLA. To put a finer point on it, you must have the anchor claim (fitting the definition of “health care”) and then make the showing that the ancillary claims are (1) contemporaneous with or related to that anchor claim; and (2) despite being ancillary, are still in the context of rendering health care.

State ex rel. W. Va. Univ. Hosps., Inc. v. Scott, 246 W. Va. 184, 194, 866 S.E.2d 350, 360

(2021).

I. Ms. Neidig’s Complaint

In her complaint, Ms. Neidig has alleged a breach of contract based on the

failure of health care services rendered, namely mammography services, to comply with

the applicable standard of care. The parties agree that mammography services are health

care. The issue in dispute in this case is that Ms. Neidig claims that she seeks only

“economic” damages for the inadequacy of the mammogram, and that, therefore, the

3 MPLA is inapplicable. However, the factual circumstances giving rise to her claims stem

from her allegations that she did not receive adequate and appropriate health care when she

received mammograms from Valley Health. While Ms. Neidig does not expressly

characterize her claim as a claim for “Medical Professional Negligence,” we have

previously held that artful pleading will not defeat the application of the MPLA. See Syl.

Pt. 4, Blankenship v. Ethicon, Inc., 221 W. Va. 700, 656 S.E.2d 451 (2007):

The failure to plead a claim as governed by the Medical Professional Liability Act, W. Va. Code § 55–7B–1, et seq., does not preclude application of the Act. Where the alleged tortious acts or omissions are committed by a health care provider within the context of the rendering of “health care” as defined by W. Va. Code § 55–7B–2(e) (2006) (Supp. 2007), the Act applies regardless of how the claims have been pled.

The Court has further stated that:

As Ethicon makes clear, a plaintiff cannot avoid the MPLA by virtue of failing to expressly allege a malpractice claim. If a claim falls squarely under the MPLA, the manner in which a complaint is drafted will not prevent the invocation of the MPLA. See, e.g., Ethicon, 221 W. Va. at 707, 656 S.E.2d at 458 (approving circuit court’s analysis that plaintiffs’ labeling “as ‘products’ claims does not change the fundamental [MPLA] basis of this tort action”); Gray v. Mena, 218 W. Va. 564, 570, 625 S.E.2d 326, 332 (2005) (permitting plaintiff who opted not to bring MPLA action opportunity to amend complaint and comply with MPLA requirements rather than upholding dismissal for non-compliance with MPLA filing requirements). As we stressed in Ethicon, “the determination of whether a cause of action falls within the MPLA is based upon the factual circumstances giving rise to the cause of action, not the type of claim asserted.” 221 W. Va. at 702–03, 656 S.E.2d at 453–54 (emphasis supplied).

4 Minnich v. MedExpress Urgent Care, Inc.-W. Va., 238 W. Va. 533, 537, 796 S.E.2d 642,

646 (2017). “It goes without saying that [a plaintiff] cannot avoid the MPLA with creative

pleading.” Scott, 246 W. Va.

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