Griffith v. Santillan

CourtDistrict Court, S.D. Texas
DecidedOctober 21, 2019
Docket3:19-cv-00053
StatusUnknown

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

Bluebook
Griffith v. Santillan, (S.D. Tex. 2019).

Opinion

□ Southern District of Texas ENTERED October 21, 2019 UNITED STATES DISTRICT COURT David J. Bradley, Clerk SOUTHERN DISTRICT OF TEXAS . □ . GALVESTON DIVISION MICHAEL DOUGLAS GRIFFITH, § □ as owner of the M/V Wellcraft Center § Console, ET AL. § § Petitioners. § § VS. § CIVIL ACTION NO. 3:19-CV—00053 □ § PAUL SANTILLAN, ET AL. § § Claimants. § .

. ORDER □

Before me is a request that I order Claimant Paul Santillan (“Santillan”) to submit ‘to an independent medical examination pursuant to Federal Rule of Civil Procedure 35 (“Rule 35”). See Dkt. 37. After reviewing the parties’ written submissions, hearing oral -

argument, and reviewing the applicable case law, I believe an independent medical examination (“IME”) is appropriate in this case. BACKGROUND This lawsuit arose from an incident that occurred during a fishing trip aboard the M/V Wellcraft Center Console Charter Boat (the “Vessel”) in the summer of 2017. According to Santillan, the driver of the Vessel accelerated to a very high rate of speed, hit the wake of a wave, and launched Santillan, a passenger on the Vessel, out of his seat. When Santillan landed back on the Vessel, he says that he struck the seat extremely hard, suffering immediate pain and injuries to his neck, lower back, and tailbone area. Santillan further alleges that the driver continued to operate the Vessel in a negligent manner and at

a high rate of speed, causing him to fly upward a second time, further aggravating his injuries. oo Petitioners Michael Douglas, Ir. and Lori Griffith, as owners of the Vessel, and Michael Coleton Griffith, individually and abla Get Fishy Charters, as owner prohac □□□□ of the Vessel (collectively “Petitioners”), invoked this Court’s admiralty jurisdiction by filing a Complaint and Petition for Exoneration From or Limitation of Liability. Santillan timely filed a claim seeking damages for personal injuries he allegedly sustained as a result □ of the incident. Petitioners have requested that Santillan undergo an IME with Dr. Michael Kaldis, a Board-Certified orthopedic surgeon. Santillan has objected to the request for an IME, □

claiming that Petitioners have failed to establish good cause for conducting such an examination. □ ANALYSIS Rule 35 provides that a district court “may order a party whose mental or physical condition . . 1s in controversy to submit to a physical or mental examination by a suitably licensed or certified examiner.” FED. R. CIv. P. 35(a). Such an order may be made “only motion for good cause and on notice to all parties and the person to be examined.” /d. □

Although an order for a physical examination is not automatically granted in all '

cases, district courts in the Fifth Circuit have uniformly held that Rule 35(a) should be construed liberally in favor of granting discovery. See, e.g., Valenzuela v. Willete, No. 5:14-cv-00062, 2015 WL 12843209, at *1 (S.D. Tex. May 15, 2015); Lahr v. Fulbright & Jaworski, LLP, 164 F.R.D. 204, 207 n.1 (N.D. Tex. 1996). Ultimately, the decision on >

whether to order an IME is left to the sound discretion of the district court. See Teche Lines.

v. Boyette, 111 F.2d 579, 581 (Sth Cir. 1940).

_ “Rule 35, as contrasted with the other discovery provisions, is distinct in its requirements that the party requesting such a mental or physical examination must affirmatively establish that the condition is ‘in controversy’ and ‘good cause’ exists for the examination, two requirements which are ‘necessarily related.’” Ornelas v. S. Tire Mart, LLC, 292 F.R.D. 388, 391 (S.D. Tex. 2013) (citation omitted). All the requirements under Rule 35(a) are satisfied in this case. A. SANTILLAN’S Conprrion Is “IN CONTROVERSY”

It is undisputed that Santillan’s medical and physical condition is “in controversy.” Indeed, Santillan has put his medical and physical condition at issue by asserting a | negligence claim. See Schlagenhauf v. Holder, 379 U.S. 104, 119 (1964) (“A plaintiff in a negligence action who asserts mental or physical injury places that mental or physical injury clearly in controversy.”) (citation omitted). A cursory glance at Santillan’s Answer, Affirmative Defenses, and Claim for Damages clearly reflects that Santillan’s medical and physical condition are of critical importance to his personal injury claim:

° “As [a] result of Mr. Griffith’s negligence, [Santillan] sustained severe personal injuries, including a compression fracture of his - second lumbar vertebra.” Dkt. 12 at 2 “Due to the gravity of the injuries stated above, [Santillan] has had to ‘seek reasonable and necessary medical caré and attention, and this has caused [Santillan] to incur reasonable and necessary medical expenses for the treatment of [Santillan’s] injuries.” Jd. at 8.

° “In all likelihood, based upon a reasonable medical probability, [Santillan] will require reasonable and necessary medical treatment

and incur reasonable and necessary medical expenses into the future.” Id. .

° “Further, [Santillan] would show he has suffered physical pain and mental anguish as a result of this incident. Such physical pain and mental anguish in all reasonable medical probability will continue into the future, if not permanently.” Jd.

e “Further, [Santillan] would show [he] has suffered physical impairment as a result of this incident. Such physical impairment in all reasonable probability will continue into the future, if not permanently.” Id. Accordingly, I find that Petitioners have established that Santillan’s physical condition is “in controversy.” B. PETITIONERS HAVE SHOWN “GOOD CAUSE” Turning to “good cause,” Petitioners must show specific facts that demonstrate a need for the information expected to be derived from the examination. See Schlagenhauf, 379 U.S. at 118. Petitioners contend that Santillan’s medical records establish a significant medical history, including 10 orthopedic surgeries due to football-related injuries. It is imperative, Petitioners argue, for a doctor to examine Santillan and assess the cause of his current injuries and determine whether Santillan, as he alleges, will face future physical impairment and medical expenses. In opposing an IME, Santillan argues that “[t]here is no good cause for Dr. Kaldis to examine Mr. Santillan because there are less invasive ways that your clients can learn about [Santillan’s] medical conditions: you have access to all of [Santillan’s] medical records and radiology films... . You can also have Dr. Kaldis watch the. videotaped

. + deposition of [Santillan].” Dkt. 37 at 2. This argument is completely unpersuasive. It

seems incredibly obvious that “[a] review of cold medical records is [simply] no substitute _ for an in-person examination by a doctor.” Hasan v. McCormack Baron Mgmt., Inc., No.

. 18-7779, 2019 WL 2122978, at *2 (E.D: La. May 15, 2019). Stated succinctly, it is patently ‘unfair for Santillan to stand in the way of an IME when he has filed a personal injury lawsuit seeking to recover more than $1 million in damages. This is especially true when |

there is a treating orthopedic physician that Santillan expects to call to testify at trial to help establish his medical condition and alleged damages. As Petitioners correctly note:

“1G]ood cause exists for the [Petitioners] to have an equal opportunity to evaluate his medical and physical condition.” Dkt. 40 at 1. I believe the purpose of Rule 35 is

provide a level playing ld and that goal would be torn asunder if Santillan’s doctor was permitted to conduct a physical examination while Petitioners’ doctor was not. .

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Related

Schlagenhauf v. Holder
379 U.S. 104 (Supreme Court, 1965)
Lewis v. Lewis & Clark Marine, Inc.
531 U.S. 438 (Supreme Court, 2001)
Teche Lines, Inc. v. Boyette
111 F.2d 579 (Fifth Circuit, 1940)
Ornelas v. Southern Tire Mart, LLC
292 F.R.D. 388 (S.D. Texas, 2013)
Looney v. National Railroad Passenger Corp.
142 F.R.D. 264 (D. Massachusetts, 1992)
Powell v. United States
149 F.R.D. 122 (E.D. Virginia, 1993)
Lahr v. Fulbright & Jaworski, L.L.P.
164 F.R.D. 204 (N.D. Texas, 1996)

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Griffith v. Santillan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/griffith-v-santillan-txsd-2019.