in Re: Mohammad Siddiqi, M.D. and Phillip A. Haynes, M.D., PH.D.

CourtCourt of Appeals of Texas
DecidedNovember 30, 2006
Docket14-06-00913-CV
StatusPublished

This text of in Re: Mohammad Siddiqi, M.D. and Phillip A. Haynes, M.D., PH.D. (in Re: Mohammad Siddiqi, M.D. and Phillip A. Haynes, M.D., PH.D.) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
in Re: Mohammad Siddiqi, M.D. and Phillip A. Haynes, M.D., PH.D., (Tex. Ct. App. 2006).

Opinion

Petitions for Writ of Mandamus Conditionally Granted and Opinion filed November 30, 2006

Petitions for Writ of Mandamus Conditionally Granted and Opinion filed November 30, 2006.

In The

Fourteenth Court of Appeals

____________

NO. 14-06-00899-CV

IN RE MEMORIAL HERMANN HOSPITAL SYSTEM D/B/A

MEMORIAL HERMANN SOUTHEAST HOSPITAL, Relator

NO. 14-06-00913-CV

IN RE MOHAMMAD SIDDIQI, M.D., AND

PHILIP A. HAYNES, M.D., PH.D., Relators

ORIGINAL PROCEEDINGS

WRIT OF MANDAMUS

O P I N I O N


Relator Memorial Hermann Hospital Systems, d/b/a Memorial Hermann Southeast Hospital (AMHHS@), and relators, Mohammad Siddiqi, M.D. and Philip A. Haynes, M.D., Ph.D. (the ADoctors@), filed petitions for a writ of mandamus in this Court, seeking relief from an order signed by respondent, the Honorable Patricia Hancock, presiding judge of the 113th Judicial District Court, Harris County, Texas, granting a petition to conduct oral depositions under Rule of Civil Procedure 202, filed by real party in interest Wendy Guzman concerning emergency medical care provided to Guzman=s son, Tristan.[1]  For the reasons discussed below, we conclude that the trial court=s order granting the oral depositions of relators in this case is an abuse of discretion for which relators have no adequate remedy by appeal.  Accordingly, in both Cause No. 14-06-00899 and Cause No. 14-06-00913, we conditionally grant the petitions for a writ of mandamus.  

Background

The mandamus record indicates that seven year-old Tristan Guzman received emergency medical treatment on two consecutive days, February 12 and February 13, 2006, at MHHS=s emergency room.  Doctor Haynes was the attending emergency room physician on February 12, and Dr. Siddiqi was the attending emergency room physician on February 13.  Nurse Tammy McCrumb also participated in Tristan=s care on February 13.  Tristan was eventually transferred to another facility, where he remained hospitalized for over two months.   

On August 23, 2006, Wendy Guzman filed a petition under Rule 202, seeking to depose the Doctors and McCrumb.  Relators filed motions to quash and objections to the petition, arguing the pre-suit depositions were prohibited under the Texas Medical Liability Act (the ATMLA@).[2]  After conducting a hearing, respondent signed an order on September 25, 2006 (the ASeptember 25 order@), stating, in part, the following:

a.     Section 74.351(s) . . . does not apply to a Rule 202 deposition because there is no health care liability claim that is being prosecuted at the present time, as no notice of claim has been given.  In re Allan, 191 S.W.3d 483 (Tex. App.CTyler 2006);


b.     An alternative basis for this order is that even if Section 74.351(s) applies to potential claims by a person who has not yet filed a notice of claim against any health care provider or physician, Section 74.351(s)(3) specifically permits discovery from nonparties under Rule 205 of the [TRCP].  Rule 205 expressly permits a Rule 202 oral deposition of a nonparty. Since no notice has been given to any party, and no claim has been instituted, all the persons whose depositions have been compelled by this order are nonparties, and therefore the Rule 202 depositions are permissible under Rule 205.

Relators seek a writ of mandamus compelling respondent to vacate the September 25 order.

Standard of Review

Mandamus relief is available when the trial court abuses its discretion or violates a legal duty, and there is no adequate remedy at law.  In re Dana Corp., 138 S.W.3d 298, 301 (Tex. 2004) (citing Walker v. Packer, 827 S.W.2d 833, 839 (Tex. 1992)).  A trial court abuses its discretion if it reaches a decision so arbitrary and unreasonable as to amount to a clear and prejudicial error of law, or if it clearly fails to correctly analyze or apply the law.  In re Cerberus Capital Mgmt., L.P., 164 S.W.3d 379, 382 (Tex. 2005).  There is no adequate remedy by appeal when an appellate court cannot remedy a trial court=s discovery error.  In re Dana Corp., 138 S.W.3d at 301; see also In re Allan, 191 S.W.3d 483, 489 (Tex. App.CTyler 2006, orig. proceeding [mand. pending]) (concluding an order granting Rule 202 depositions of health care parties against whom a suit is contemplated is interlocutory and not a final, appealable order).     

Discussion

Relators argue that the express language of subsections 74.351(s) and (u), and the legislative intent underlying the TMLA, preclude pre-suit oral depositions of health care defendants.  They assert that, by allowing Guzman to conduct the pre-suit oral depositions, the trial court has interpreted Rule 202 as controlling over the statute=s provisions, violating section 74.002.[3] 


Contrarily, Guzman argues that the TMLA does not prohibit the pre-suit oral depositions because the statute does not apply to Apotential@ health care claims, and she is not a Aclaimant@ as defined in the statute.  Guzman argues that, even assuming the TMLA is applicable, section 74.351 and Rule 205 expressly permit oral depositions of nonparty witnesses through a Rule 202 petition.[4]

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Related

In Re Dana Corp.
138 S.W.3d 298 (Texas Supreme Court, 2004)
In Re Cerberus Capital Management, L.P.
164 S.W.3d 379 (Texas Supreme Court, 2005)
Sultan v. Mathew
178 S.W.3d 747 (Texas Supreme Court, 2005)
IFS Security Group, Inc. v. American Equity Insurance Co.
175 S.W.3d 560 (Court of Appeals of Texas, 2005)
In Re Allan
191 S.W.3d 483 (Court of Appeals of Texas, 2006)
In Re Raja
216 S.W.3d 404 (Court of Appeals of Texas, 2006)
Walker v. Packer
827 S.W.2d 833 (Texas Supreme Court, 1992)

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in Re: Mohammad Siddiqi, M.D. and Phillip A. Haynes, M.D., PH.D., Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-mohammad-siddiqi-md-and-phillip-a-haynes-md--texapp-2006.