Hall v. United States

CourtDistrict Court, E.D. Kentucky
DecidedJuly 16, 2024
Docket5:22-cv-00113
StatusUnknown

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

Bluebook
Hall v. United States, (E.D. Ky. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY CENTRAL DIVISION AT LEXINGTON

CASE NO. 5:22-CV-113-KKC

ESTATE OF WILLIAM COLT HALL, by and through its Administratrix, Christina Hall, et al., PLAINTIFFS,

v. OPINION AND ORDER

UNITED STATES OF AMERICA, et al., DEFENDANTS.

* * * * * * * * * This matter is before the Court on a motion to decline jurisdiction and dismiss (DE 34) filed by Defendants Saint Joseph Health System, Inc. and Saint Joseph Mount Sterling (collectively, “Saint Joseph”). For the following reasons, the Court will deny Saint Joseph’s motion to decline jurisdiction and dismiss. I. BACKGROUND This action for medical negligence arises out of the 2020 labor and delivery of infant William Colt Hall (“Colt”) at Saint Joseph in Mount Sterling, Kentucky. The Estate of William Colt Hall (the “Estate”) initially filed a lawsuit against Saint Joseph in Montgomery Circuit Court on November 3, 2021. In its state action, the Estate asserts that Saint Joseph nurses were negligent in the monitoring of the labor before and during the emergency c-section. Subsequently, the Estate filed an action under the Federal Tort Claims Act (FTCA), 28 U.S.C. § 2671, against the United States in this Court on May 3, 2022. The Estate alleges negligence in the handling of the birth against Dr. Byram Ratliff, M.D., and Shane Hirst, CNM, both of which are employed by the United States. The Estate later amended its complaint to include Saint Joseph as defendants and to incorporate allegations against Saint Joseph nurses almost identical to those found in its state-court complaint. Discovery for both the state and federal actions have commenced—with the parties coordinating and taking depositions for purposes of both actions. Further, counsel from both state and federal cases have been participating in the discovery process. On December 6, 2023, Saint Joseph filed a motion to dismiss (DE 34) that asks the Court to abstain from hearing this case because of the existence of the concurrent state-court proceedings.1 The Estate responded to the motion and Saint Joseph filed a reply. (DEs 36, 37.) Now that the motion is ripe for review, the Court turns to Saint Joseph’s argument for

abstention under the Colorado River doctrine. II. ANALYSIS. Saint Joseph asks that the Court abstain from hearing this case pursuant to the Colorado River doctrine. Under this doctrine, abstention from a case by a federal court is permissible when: (1) there is “parallel” litigation pending in state and federal courts; and (2) the proposed litigation in federal court would be duplicative or unwise. Colorado River Water Conservation Dist. v. United States, 424 U.S. 800, 817–18 (1976). A. Parallel Litigation “Before the Colorado River doctrine can be applied, the district court must first determine that the concurrent state and federal actions are actually parallel.” Romine v. Compuserve Corp., 160 F.3d 337, 339 (6th Cir. 1998). “[E]xact parallelism” is not required; “[i]t is enough if two proceedings are substantially similar.” Id. at 340 (citing Nakash v. Marciano, 882 F.2d 1411, 1416 (9th Cir. 1989); Interstate Material Corp. v. City of Chicago, 847 F.2d 1285, 1288 (7th Cir. 1988); Lumen Constr., Inc. v. Brant Constr. Co., 780 F.2d 691, 695 (7th Cir.

1 Specifically, Saint Joseph asks that the Court abstain from hearing the state-law claims found in the Estate’s amended complaint. The Court has found no case law suggesting that it can abstain from only some claims under the Colorado River doctrine. Accordingly, the Court will interpret the motion as requesting abstention from the case in its entirety. 1985)). Where the parties are substantially similar and the claims raised in both suits are predicated on the same allegations as to the same material facts, the two actions are considered parallel for the purposes of Colorado River abstention. Id. Further, “the argument that abstention is inappropriate because the federal cause of action included parties not present in the state proceedings is not relevant to Colorado River abstention.” Id. (quotation marks omitted). Here, the state and federal proceedings are sufficiently parallel because both complaints are predicated on the same factual allegations. The labor, delivery, and unfortunate death of

infant Colt gave rise to both actions. Both actions pursue claims against Saint Joseph through the actions of its employees. In fact, the factual allegations in the amended federal complaint are identical to the factual allegation in the state complaint. That state courts do not have jurisdiction to hear the FTCA claims is no bar to abstention as long as the material facts underlying the claims and the parties are substantially similar. Id. Such is the case here. Accordingly, the Court finds that the two actions are sufficiently parallel. B. Colorado River Factors Given that the state and federal proceedings are sufficiently parallel, the Court must consider the following factors: (1) whether the state court has assumed jurisdiction over any res or property; (2) whether the federal forum is less convenient to the parties; (3) avoidance of piecemeal litigation; (4) the order in which jurisdiction was obtained; (5) whether the source of governing law is state or federal; (6) the adequacy of the state court action to protect the federal plaintiff’s rights; (7) the relative progress of the state and federal proceedings; and (8) the presence or absence of concurrent jurisdiction. Healthcare Co. Ltd. v. Upward Mobility, Inc., 784 F. App’x 390, 395 (6th Cir. 2019). These factors are not a mechanical checklist; rather, they are considerations that must be carefully balanced in a given case, “with the balance heavily weighted in favor of the exercise of jurisdiction.” Moses H. Cone Mem’l Hosp. v. Mercury Const. Corp., 460 U.S. 1, 16 (1983). First, it is undisputed that the state court has not assumed jurisdiction over any res or property in this matter. The Sixth Circuit has explained in Romine v. Compuserve Corp., which Saint Joseph heavily relies on in its motion, that this factor “weighs against abstention” when there is no res or property at issue. 160 F.3d 337, 341 (6th Cir. 1998). Accordingly, this factor weighs against abstention. Second, the federal forum would be slightly less convenient to the parties because “Saint Joseph is located in Mount Sterling, Kentucky” and “this matter will undoubtedly involve several hospital witnesses who reside in or around the Montgomery County area.” (DE

34-1 at 4.) The Estate does not contest these facts and instead claims that it only intends to call one Saint Joseph witness and requiring them to travel 30 miles “is not so burdensome.” (DE 36 at 8.) Yet Saint Joseph is correct in noting that there is nothing binding the Estate to its claim of calling only one witness. Further, this factor “relates to geographical considerations[.]” PaineWebber, Inc. v. Cohen, 276 F.3d 197, 207 (6th Cir. 2001).

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Hall v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hall-v-united-states-kyed-2024.