Hugh Keith McWhorter v. Baptist Healthcare System, Inc. D/B/A Baptist Health Lexington

CourtKentucky Supreme Court
DecidedFebruary 14, 2024
Docket2022 SC 0354
StatusUnknown

This text of Hugh Keith McWhorter v. Baptist Healthcare System, Inc. D/B/A Baptist Health Lexington (Hugh Keith McWhorter v. Baptist Healthcare System, Inc. D/B/A Baptist Health Lexington) 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
Hugh Keith McWhorter v. Baptist Healthcare System, Inc. D/B/A Baptist Health Lexington, (Ky. 2024).

Opinion

RENDERED: FEBRUARY 15, 2024 TO BE PUBLISHED

Supreme Court of Kentucky 2022-SC-0354-DG

HUGH KEITH MCWHORTER; APPELLANTS AND CAROL MCWHORTER

ON REVIEW FROM COURT OF APPEALS NO. 2021-CA-0844 V. FAYETTE CIRCUIT COURT NO. 21-CI-00532

BAPTIST HEALTHCARE SYSTEM, INC. APPELLEE D/B/A BAPTIST HEALTH LEXINGTON

OPINION OF THE COURT BY JUSTICE CONLEY

AFFIRMING

Keith McWhorter and his wife, Carol, filed a lawsuit 1 against Baptist

Healthcare System, Inc., d/b/a Baptist Health Lexington (BHL). BHL filed a

motion to dismiss arguing that the McWhorters failed to file a certificate of

merit as required by KRS 2 411.167. The trial court dismissed the case with

prejudice, which the McWhorters appealed. The Court of Appeals affirmed the

dismissal of the trial court. McWhorter then filed a motion for discretionary

1 Keith’s claim alleged medical negligence, while Carol’s claim was based on loss

of consortium. 2 Kentucky Revised Statutes. review with this Court which we granted. Upon review, we hereby affirm the

Court of Appeals. 3

I. FACTS AND PROCEDURAL ISSUES

The Kentucky General Assembly passed House Bill 429 (HB 429) in

2019, which became effective on June 27, 2019. This law was passed in order

to ease the perceived burden on medical providers from meritless lawsuits. It

was codified as KRS 411.167. On February 17, 2021, the McWhorters filed

their complaint but did not include a certificate of merit. BHL filed an answer

on March 3, 2021. On May 25, 2021, BHL filed a motion to dismiss on the

grounds the McWhorters failed to comply with KRS 411.167 by omitting to file

a certificate of merit with the complaint. In response, the McWhorters

requested additional time in which to file a certificate of merit. The McWhorters

argued KRS 411.167(2)(b) 4 permits a court to grant an extension to file a

certificate of merit upon a showing of good cause. The McWhorters belatedly

filed a certificate of merit on June 3, 2021. After a hearing held on June 11, the

trial court issued an order entered on June 21, 2021, denying the McWhorters’

3 This case addresses the same issues as Sanchez v. McMillin, M.D., et al., 2022-

SC-0272-DG, 2022-SC-0274-DG, which was heard the same day. Therefore, this opinion treads similar ground. 4 “The claimant was unable to obtain the consultation required by paragraph (a)

of this subsection because a limitation of time established by KRS Chapter 413 would bar the action and that the consultation could not reasonably be obtained before that time expired. An affidavit or declaration executed pursuant to this paragraph shall be supplemented by an affidavit or declaration pursuant to paragraph (a) of this subsection or paragraph (c) of this subsection within sixty (60) days after service of the complaint or the suit shall be dismissed unless the court grants an extension for good cause[.]” 2 requested extension of time and ordering the complaint dismissed with

prejudice.

The McWhorters filed a timely appeal where the Court of Appeals heard

the case. At the Court of Appeals, the McWhorters abandoned their previous

argument before the trial court that KRS 411.167(2)(b) permitted an extension

of time to file a certificate of merit. Instead, the McWhorters argued that they

had complied under KRS 411.167(7). 5 The McWhorters also argued, at the

Court of Appeals but not at the trial court, that the defendants waived the

certificate of merit argument by not including it in their initial answer. The

Court of Appeals addressed the McWhorters’ argument but held that in order

to comply with KRS 411.167(7), the plaintiff must file the information with the

complaint. The Court of Appeals also held that the defendant did not waive the

certificate of merit issue. The McWhorters filed a motion for discretionary

review, which we then granted. We now address the appeal.

II. ANALYSIS

The McWhorters argue in their briefs before this Court that they

complied with the requirements imposed by KRS 411.167 both technically and

substantially under subsection 7. They further argue that BHL failed to raise

the McWhorters’ purported failure to file a certificate of merit as a defense in

BHL’s answer. Therefore, they insist, the issue should be considered waived.

Also, they claim that the trial court abused its discretion by not allowing the

5 “The claimant, in lieu of serving a certificate of merit, may provide the defendant or

defendants with expert information in the form required by the Kentucky Rules of Civil Procedure. Nothing in this section requires the disclosure of any ‘consulting’ or nontrial expert, except as expressly stated in this section.”

3 McWhorters to file the certificate of merit late under CR 6 6.02. Lastly, the

McWhorters allude to the unconstitutionality of KRS 411.167, should this

Court not interpret the statute in their favor.

As noted above, the only issue raised before the trial court was that the

McWhorters had indeed complied under KRS 411.167(2)(b). Furthermore, the

McWhorters completely abandoned this argument both before the Court of

Appeals and now before this Court. Of the remaining issues, only the

McWhorter’s claim that they complied with subsection 7 by supplying expert

information as contemplated by the Kentucky Rules of Civil Procedure and the

issue of waiver were even raised before the Court of Appeals. 7

The Kentucky Rules of Appellate Procedure require an appellant to

include:

An argument conforming to the statement of points and authorities, with ample references to the specific location in the record and citations of authority pertinent to each issue of law and which shall contain at the beginning of the argument a statement with reference to the record showing whether the issue was properly preserved for review and, if so, in what manner.

RAP 32(A)(4) (emphasis added). The McWhorters included in their brief, in a

footnote, a statement claiming that these issues were preserved and cited to

6 Kentucky Rules of Civil Procedure.

7 This Court’s conclusion that the issue of waiver was raised before the Court of

Appeals is generous considering that this issue was lumped in with McWhorters claim of compliance under KRS 411.167(7).

4 the record. 8 Upon review of the record, these arguments before the trial court

pertain solely to Appellant’s request for an extension of time under KRS

411.167(2)(b) and not any other issue.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Little v. Whitehouse
384 S.W.2d 503 (Court of Appeals of Kentucky (pre-1976), 1964)

Cite This Page — Counsel Stack

Bluebook (online)
Hugh Keith McWhorter v. Baptist Healthcare System, Inc. D/B/A Baptist Health Lexington, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hugh-keith-mcwhorter-v-baptist-healthcare-system-inc-dba-baptist-ky-2024.