Irving W. Marks v. St. Luke's Episcopal Hospital

CourtTexas Supreme Court
DecidedAugust 28, 2009
Docket07-0783
StatusPublished

This text of Irving W. Marks v. St. Luke's Episcopal Hospital (Irving W. Marks v. St. Luke's Episcopal Hospital) is published on Counsel Stack Legal Research, covering Texas Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Irving W. Marks v. St. Luke's Episcopal Hospital, (Tex. 2009).

Opinion

IN THE SUPREME COURT OF TEXAS

IN THE SUPREME COURT OF TEXAS

════════════

No. 07-0783

Irving W. Marks, Petitioner,

v.

St. Luke’s Episcopal Hospital, Respondent

════════════════════════════════════════════════════

On Petition for Review from the

Court of Appeals for the First District of Texas

Argued September 11, 2008

            Justice Johnson, joined by Justice Hecht, Justice Wainwright, and Justice Willett, dissenting.

            The Court today allows a health care liability claim to go forward despite Marks’s failure to comply with the Medical Liability Insurance Improvement Act (MLIIA or Act). It does so by (1) condoning the recasting of a claim by a patient based on an injury caused by specialized hospital equipment into a non-health care claim by artful pleadings; and (2) misconstruing plain, unambiguous statutory language. I dissent.

            Marks underwent surgery at St. Luke’s Hospital to implant a morphine pump into his spinal cord after multiple previous surgeries failed to alleviate his back problems. After surgery, the nursing staff made a notation in his medical records that he was at risk of falling because of his limited mobility, his need for an ambulatory assistance device, and the fact he was on morphine, and “Safety/Fall Precautions” were being implemented. The hospital’s Safety/Fall Precautions included provisions that there should be “no environmental hazards” in Marks’s room, his hospital bed was to be “in a low position with the brakes applied,” and the “side rails and safety devices” should be used as indicated. Marks alleges that seven days after his surgery and while still an inpatient, he and the footboard on his hospital bed fell when he placed his hand on the footboard and attempted to push himself from the bed to a standing position.

            Marks sued St. Luke’s. He alleged the hospital was negligent in the following respects: (1) failing to properly train and supervise hospital employees in how to prevent falls and injuries; (2) failing to provide Marks with the assistance he required for daily living activities; (3) failing to provide him with a safe environment in which to receive treatment and recover; and (4) providing him with a hospital bed that had been negligently assembled and maintained by the hospital’s employees or nursing staff. The Court holds, and I agree, that the first three claims are health care liability claims that fall under the MLIIA. But, unlike the Court, I would hold that the entire suit is a health care liability claim subject to the procedures and limitations set out in the Act.

            In order to preclude Marks’s suit from being subject to the MLIIA, the Court must, and does, reach three conclusions with which I disagree. The first is that one injury based on a single set of facts can, by the manner in which pleadings are formulated, be both a health care liability claim and a non-health care liability claim. The second is that a hospital bed furnished to a post-surgery hospital inpatient is not an inseparable part of health care provided by the hospital. The third is that accepted standards of hospital safety do not include providing safe hospital beds to patients confined in the hospital.

            First, the Court’s holding allows a cause of action by a patient against a health care provider to be both a health care claim and a non-health care claim, even though the action arises from a single injury based on a single set of facts. The Court concludes that because of the manner in which Marks pleads his suit, three of his liability theories are health care liability claims while the other is a premises liability claim that is not subject to the MLIIA. In Diversicare, the concurring and dissenting justices similarly concluded that the victim of sexual assault at a nursing home asserted a premises liability claim against the nursing home independent of her health care liability claim. Diversicare Gen. Partner, Inc. v. Rubio, 185 S.W.3d 842, 857-58 (Tex. 2005) (Jefferson, C.J., concurring in part, and dissenting in part); id. at 861-66 (O’Neill, J., dissenting). The Court rejected that view because it “would open the door to splicing health care liability claims into a multitude of other causes of action with standards of care, damages, and procedures contrary to the Legislature’s explicit requirements. It is well settled that such artful pleading and recasting of claims is not permitted.” Id. at 854; see also Murphy v. Russell, 167 S.W.3d 835, 838 (Tex. 2005) (“[A] claimant cannot escape the Legislature’s statutory scheme by artful pleading.”); Garland Cmty. Hosp. v. Rose, 156 S.W.3d 541, 543 (Tex. 2004) (“Plaintiffs cannot use artful pleading to avoid the MLIIA’s requirements when the essence of the suit is a health care liability claim.”). The Court today circumvents explicit language the Court used in Diversicare and other cases rejecting this type of claim-splitting by pleadings. The holding will inevitably open the door to manipulated, inventive, and artful pleading designed to avoid the MLIIA requirements and limitations by recasting of claims.

            Allowing this type of claim-splitting almost assuredly will lead to more extended and expensive trial court proceedings to determine whether a patient’s pleadings assert health care liability claims subject to the MLIIA, non-health care liability claims, or both; and if both, which is which. As this appeal shows, there will be more extended and expensive appellate proceedings for the same purpose. Extended judicial proceedings and associated increased costs, including “economic” settlements to avoid litigation expense, are a significant part of what the Legislature intended to avoid through enactment of the MLIIA. See former Tex. Rev. Civ. Stat. art. 4590i, § 1.02(b)(2);1 see also id. § 1.02(b)(1).

            The most appropriate course in circumstances such as these is the course the Court has taken before today: when the substance of a patient’s claim for injury comes within the statutory definition of a health care liability claim, then the MLIIA applies to all the plaintiff’s claims against the health care provider based on that injury.

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