J.B. Hunt Transport, Inc. v. Forrest General Hospital

CourtMississippi Supreme Court
DecidedAugust 26, 2008
Docket2008-CA-02111-SCT
StatusPublished

This text of J.B. Hunt Transport, Inc. v. Forrest General Hospital (J.B. Hunt Transport, Inc. v. Forrest General Hospital) is published on Counsel Stack Legal Research, covering Mississippi Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
J.B. Hunt Transport, Inc. v. Forrest General Hospital, (Mich. 2008).

Opinion

IN THE SUPREME COURT OF MISSISSIPPI

NO. 2008-CA-02111-SCT

J. B. HUNT TRANSPORT, INC.

v.

FORREST GENERAL HOSPITAL

DATE OF JUDGMENT: 08/26/2008 TRIAL JUDGE: HON. ROBERT B. HELFRICH COURT FROM WHICH APPEALED: FORREST COUNTY CIRCUIT COURT ATTORNEYS FOR APPELLANT: MORTON W. SMITH DAVID C. DUNBAR ATTORNEYS FOR APPELLEE: R. MARK HODGES KIMBERLY N. HOWLAND NATURE OF THE CASE: CIVIL - OTHER DISPOSITION: AFFIRMED - 05/20/2010 MOTION FOR REHEARING FILED: MANDATE ISSUED:

EN BANC.

LAMAR, JUSTICE, FOR THE COURT:

¶1. J.B. Hunt Transport, Inc. (“J.B. Hunt”) filed suit against George E. McGee, M.D., and

Forrest General Hospital (“FGH”) asserting claims of negligence, medical malpractice, and

common-law indemnity arising from the treatment of Melissa Hall, who was injured in an

automobile accident by a tractor-trailer owned and operated by J.B. Hunt.1 J.B. Hunt

negotiated a settlement with Hall’s estate and wrongful-death beneficiaries before filing the

1 Dr. McGee was subsequently dismissed. instant action. The trial court granted FGH’s motion to dismiss, and J.B. Hunt appeals.

Finding no error, we affirm.

FACTS AND PROCEDURAL HISTORY

¶2. On March 8, 2006, Melissa Hall was seriously injured in a motor-vehicle accident

involving a tractor-trailer operated by J.B. Hunt. Hall was transported by ambulance to the

emergency room at Forrest General Hospital, where she was diagnosed with a closed head

injury, as well as other injuries. Hall subsequently was admitted to the intensive-care unit.

¶3. On March 11, doctors attempted unsuccessfully to wean Hall from a ventilator. On

March 14, a spontaneous breathing trial proved unsuccessful, and Hall remained dependent

on sedation and a ventilator.

¶4. On the morning of March 16, Hall underwent a tracheostomy to provide long-term

access for the breathing tube utilized by the ventilator. However, no order was given that the

tracheostomy tube be suctioned periodically. Over the next twelve hours, the tube was

suctioned only twice, despite several notations that Hall had developed a severe, productive

cough after insertion of the tube. At 10:00 p.m., having gone seven and one-half hours since

the tube was last suctioned, Hall began coughing while being bathed by a nurse, dislodging

the tube. Attempts to suction and reinsert the tube were unsuccessful, and Hall went into

cardiopulmonary arrest. After failed attempts to resuscitate her, she was pronounced dead

at 10:22 p.m.

¶5. After entering into a settlement agreement with Hall’s estate and wrongful-death

2 beneficiaries, J.B. Hunt filed the action at issue in this case, asserting claims of negligence,

medical malpractice, and common-law indemnity, and averring that “the wrongful death of

Melissa Hall arose distinctly and exclusively as a result of the conduct of the Defendants and

not from any actions or omissions of Hunt.” J.B. Hunt further asserted that it was “forced

to pay as a matter of law and under duress a significant sum for the damages caused by the

Defendants and did so as a result of formal claims by counsel for [Hall’s] family.” Finally,

J.B. Hunt asserted that it had “an implied or common law indemnity claim under Mississippi

law against the Defendants and, therefore, [had] standing to bring [the] action.” J.B. Hunt

sought damages as follows:

As a direct and proximate result of the Defendants’ conduct, Plaintiff has paid additional consideration and is entitled to recover from the Defendants the value attributable to the following:

a. Melissa’s additional pain and suffering on March 16, 2006, preceding her death;

b. Melissa’s mental anguish on March 16, 2006, preceding her death;

c. Melissa’s resulting medical expenses associated with the code and her death;

d. Melissa’s funeral and burial expenses;

e. Melissa’s life expectancy and loss of enjoyment of life;

f. Melissa’s wrongful death; and

g. All elements of damage permitted by law and available under the Mississippi Code Annotated of 1972, as amended.

3 ¶6. FGH moved to dismiss the complaint for failure to state a claim pursuant to

Mississippi Rule of Civil Procedure 12(b)(6). The trial court granted the motion, finding that

J.B. Hunt did not have standing to bring the action “based solely on its indemnity claim,” as

“‘a claim for indemnity does not arise until there is legal liability to pay a judgment in favor

of [the plaintiff.]’” (quoting Mississippi Transp. Comm’n v. Jenkins, 699 So. 2d 597 (Miss.

1997)). The trial court further held that J.B. Hunt was not a beneficiary under the wrongful-

death statute and, as such, “lacked standing to bring the claim upon which any right of

indemnification depends . . . . ”

¶7. From this judgment, J.B. Hunt appeals, asserting: (1) that the trial court erred when

it found that J.B. Hunt did not have standing to bring a common-law indemnity suit against

FGH, and (2) that the trial court erred when it found that J.B. Hunt sought indemnity for

severed aspects of a wrongful-death claim. Finding the first issue dispositive, we decline to

address the second issue.

ANALYSIS

¶8. This Court employs a de novo standard when reviewing a motion to dismiss under

Rule 12(b)(6) of the Mississippi Rules of Civil Procedure. Rose v. Tullos, 994 So. 2d 734,

737 (Miss. 2008) (citing Cook v. Brown, 909 So. 2d 1075, 1077-78 (Miss. 2005)). Such a

motion for failure to state a claim challenges the legal sufficiency of the complaint. Id. In

order to affirm an order granting dismissal on a Rule 12(b)(6) motion, “[t]he allegations in

the complaint must be taken as true, and there must be no set of facts that would allow the

plaintiff to prevail.” Wilbourn v. Equitable Life Assurance Soc’y of the U.S., 998 So. 2d

4 430, 435 (Miss. 2008) (citing Ralph Walker, Inc., v. Gallagher, 926 So. 2d 890, 893 (Miss.

2006)).

¶9. The question presented by this appeal is whether J.B. Hunt, a negligent tortfeasor in

a motor-vehicle accident which resulted in serious injuries to Melissa Hall, can seek

indemnity from a health-care provider (FGH) whose subsequent negligent medical treatment

of Hall, according to the allegations of the Complaint, caused Hall’s death. We hold that,

under the facts before us, an action for indemnity may not be brought and affirm the trial

court’s dismissal.

¶10. This Court has set forth the basis for a claim of indemnity as follows:

An obligation to indemnify may arise from a contractual relation, from an implied contractual relation or out of liability imposed by law. When one person is required to pay money which another person in all fairness should pay, then the former may recover indemnity from the latter in the amount which he paid, provided the person making the payment has not conducted himself in a wrongful manner so as to bar his recovery.

Bush v. City of Laurel, 215 So. 2d 256, 259-60 (Miss. 1968) (emphasis added).

¶11. Further, this Court has said that:

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