Harold Merritt v. Catholic Health Initiatives, Inc.

CourtKentucky Supreme Court
DecidedDecember 11, 2020
Docket2018 SC 0155
StatusUnknown

This text of Harold Merritt v. Catholic Health Initiatives, Inc. (Harold Merritt v. Catholic Health Initiatives, Inc.) is published on Counsel Stack Legal Research, covering Kentucky Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Harold Merritt v. Catholic Health Initiatives, Inc., (Ky. 2020).

Opinion

RENDERED: DECEMBER 17, 2020 TO BE PUBLISHED

Supreme Court of Kentucky 2018-SC-0155-DG

HAROLD MERRITT, INDIVIDUALLY, AND APPELLANTS AS COURT-APPOINTED ADMINISTRATOR OF THE ESTATE OF KIMBERLY MERRITT, AND AS COURT-APPOINTED ADMINISTRATOR AND NEXT FRIEND OF THE ESTATE OF HAROLD MERRITT, III

ON REVIEW FROM COURT OF APPEALS V. NO. 2016-CA-1470 FAYETTE CIRCUIT COURT NO. 15-CI-03690

CATHOLIC HEALTH INITIATIVES, INC., APPELLEES AND FIRST INITIATIVES INSURANCE, LTD.

OPINION OF THE COURT BY JUSTICE HUGHES

AFFIRMING

Appellant Harold Merritt, individually and as administrator of the Estates

of Kimberly Merritt and Harold Merritt, III (Merritt) brought a medical

negligence action against various healthcare defendants following the deaths of

his wife and newborn son. The medical negligence claims were settled, and the

Fayette Circuit Court subsequently denied Merritt’s motion for declaratory

relief as to his bad faith insurance claim against First Initiatives Insurance,

Ltd. (First Initiatives), a foreign captive insurance entity that provides self-

insurance for Catholic Health Initiatives, Inc. (Catholic Health). The Court of

Appeals affirmed both that ruling and the trial court’s grant of summary 1 judgment to First Initiatives and Catholic Health. On discretionary review, the

sole issue before this Court is whether First Initiatives, as a captive insurer, is

subject to the Kentucky Unfair Claims Settlement Practices Act (UCSPA).

Kentucky Revised Statutes (KRS) 304.12-230. Finding that the Legislature has

clearly and unequivocally excluded captive insurers from the requirements of

the UCSPA, we affirm the Court of Appeals.

FACTS AND PROCEDURAL BACKGROUND

On October 7, 2015, Harold Merritt, Jr., filed a complaint alleging that

Dr. Anthony Smith, an employee of KentuckyOne Health, breached the medical

standard of care and was ultimately responsible for the deaths of his wife,

Kimberly, and infant son, Harold Merritt, III. In 2014 Kimberly, an expectant

mother, developed placenta previa, a condition which can cause severe

bleeding during pregnancy.1 She was referred to a high-risk obstetrician who

recommended that the baby be delivered by caesarian section no later than

thirty-seven weeks gestation. Merritt alleges that despite having this

information from the high-risk obstetrician, Dr. Smith examined Kimberly

Merritt when she was at thirty-seven weeks and six days gestation and did not

perform nor schedule a caesarian section. Instead, he scheduled an

appointment to see Kimberly in one week.

In the early morning of April 10, 2015, Kimberly called Merritt and said

she was bleeding and that something was wrong. After the line suddenly went

dead, Merritt called 911. Upon arrival, Emergency Medical Services (EMS)

1 Placenta previa occurs when a baby’s placenta partially or totally covers the mother’s cervix, which can cause severe bleeding during pregnancy and delivery. Mayo Clinic, Placenta Previa (May 30, 2020), https://www.mayoclinic.org/diseases- conditions/placenta-previa/symptoms-causes/syc-20352768. 2 found Kimberly unresponsive. She died shortly after being transported to the

hospital by EMS. Harold Merritt, III, was delivered by post-mortem caesarian

section but only survived a few hours after suffering from seizures due to

complications from lack of oxygen.

In his complaint, Merritt alleged that Dr. Smith breached the standard of

care by not acting in accordance with the high-risk obstetrician’s

recommendation. Merritt named as additional defendants St. Joseph Hospital,

KentuckyOne Health, KentuckyOne Health Obstetrics and Gynecology

Associates and St. Joseph Obstetrics and Gynecology (hereinafter collectively

referred to as “the medical defendants”). Merritt also named as defendants

Catholic Health, an entity that sponsors KentuckyOne Health and its affiliates,

and First Initiatives, which provides self-insurance coverage to Catholic Health,

its affiliates and employees, including KentuckyOne Health and Dr. Smith.

First Initiatives is a wholly owned subsidiary of Catholic Health. Pursuant to

one self-insurance agreement, First Initiatives covers all of Catholic Health’s

subsidiaries and their employees for employment-related conduct. Only

Catholic Health pays assessments to First Initiatives for the provision of its

self-insurance program—Catholic Health’s affiliates do not pay for the coverage.

Merritt brought negligence, fraud, and Kentucky Consumer Protection

Act claims against First Initiatives. Merritt also maintained that First

Initiatives violated the UCSPA, KRS 304.12-230, by engaging in bad faith

settlement negotiations.

On November 16, 2015, Merritt filed a motion for declaratory judgment

seeking a declaration that First Initiatives is subject to the UCSPA and civil

liability for any violations of the statute. Merritt claimed that First Initiatives 3 refused to negotiate the claims for the deaths of Kimberly and Harold Merritt,

III, separately, instead offering a consolidated settlement for both. Additionally,

Merritt alleged that First Initiatives attempted to leverage the undisputed

claims of Harold Merritt, III, in order to settle the disputed claims of Kimberly.

He also stated that First Initiatives failed to timely respond to settlement

demands and provided no basis for denying various settlement demands.

Despite First Initiatives’ claims that it is not subject to the UCSPA,

Merritt maintained that First Initiatives does not self-insure Catholic Health

and is actually in the business of insurance because it issued a policy to

KentuckyOne Health and Catholic Health. Merritt also argued that First

Initiatives has an independent corporate identity distinct from that of Catholic

Health that renders self-insurance between the two entities impossible. With

this approach, Merritt insisted First Initiatives is not a captive insurer under

Kentucky law. Merritt filed an amended complaint on November 23, 2015 to

include this particular declaratory judgment argument.

First Initiatives responded to the declaratory judgment motion, arguing

that as a captive insurance company, it is exempt from the UCSPA.

Specifically, First Initiatives contended the captive insurance agreement

between Catholic Health and First Initiatives does not involve risk shifting or

risk distribution like ordinary insurance, and First Initiatives is not in the

business of insurance. First Initiatives also claimed that the motion was not

ripe for review because the underlying claim of medical negligence had not

been adjudicated or resolved.

On December 1, 2015 the trial court granted Catholic Health and First

Initiatives’ motion to bifurcate the bad faith claims from the underlying 4 negligence claims. The trial court also stayed all discovery concerning Merritt’s

bad faith claims pending a January 22, 2016 hearing on Merritt’s motion for

declaratory judgment and other issues.

At that time, Merritt insisted that the declaratory judgment issue was

ripe for a prompt ruling and posited that if the trial court ruled that First

Initiatives was subject to the UCSPA, then all pending claims would be

resolved. The trial court conducted hearings on January 22, March 10, and

May 6, 2016 on various issues, including declaratory judgment. On May 2,

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