Keith Salters, Etc. v. South Mountain Rehabilitation Center, LLC

CourtNew Jersey Superior Court Appellate Division
DecidedJune 17, 2025
DocketA-1790-23
StatusUnpublished

This text of Keith Salters, Etc. v. South Mountain Rehabilitation Center, LLC (Keith Salters, Etc. v. South Mountain Rehabilitation Center, LLC) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Keith Salters, Etc. v. South Mountain Rehabilitation Center, LLC, (N.J. Ct. App. 2025).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-1790-23

KEITH SALTERS, a/k/a KEITH LAMONT SALTERS, as Executor of the ESTATE OF RAYMOND SALTERS,

Plaintiff-Appellant,

v.

SOUTH MOUNTAIN REHABILITATION CENTER, LLC, OCEAN HEALTHCARE, LLC, d/b/a SOUTH MOUNTAIN REHABILITATION CENTER, and OCEAN HEALTHCARE MANAGEMENT, LLC,

Defendants-Respondents. ______________________________

Submitted May 21, 2025 – Decided June 17, 2025

Before Judges Mayer and Puglisi.

On appeal from the Superior Court of New Jersey, Law Division, Union County, Docket No. L-2309-20.

Hinson Snipes LLP, attorneys for appellant (Tracey C. Hinson and Eric D. Dakhari, on the briefs). Burns White LLC, attorneys for respondents (William C. Mundy, Monica C. Fillmore, and Clayton R. Fritsch, on the brief).

Stark & Stark, PC, attorneys for amicus curiae The New Jersey Association for Justice (Jonathan F. Lauri, of counsel and on the brief).

PER CURIAM

Plaintiff Keith Salters, as executor of the Estate of Raymond Salters,1

appeals from the following orders: an April 28, 2023 order granting a motion by

defendants South Mountain Rehabilitation Center, LLC (South Mountain),

Ocean County Healthcare, LLC d/b/a South Mountain Rehabilitation Center,

and Ocean Healthcare Management, LLC (collectively, defendants) to bar a

supplemental expert report authored by Dr. Carol White; an October 23, 2023

order partially granting defendants' motion for summary judgment; and a

January 19, 2024 order granting defendants' motion to bar the trial testimony of

Drs. James Lee and Shailender Karry and reconsidering the October 23 order

for partial summary judgment, resulting in the dismissal of plaintiff's entire

complaint with prejudice. For the reasons that follow, we affirm in part and

reverse in part.

1 We refer to Raymond Salters as decedent. A-1790-23 2 On September 15, 2019, decedent fell in his room at the South Mountain

nursing facility. He explained he fell while attempting to retrieve an item from

his refrigerator. Decedent lived at South Mountain from August 2019 to

November 2019.

According to progress notes maintained by South Mountain, the facility's

staff discovered decedent lying on the floor near his bed at about 12:40 a.m.

According to the incident report, a nursing assistant was in decedent's room just

prior to his fall but left to respond to another patient's call bell around 12:30

a.m. After his fall, staff members assessed decedent's condition and returned

him to his bed. The notes indicated decedent did not complain of pain

immediately after falling but reported hip pain earlier that day. The notes also

stated decedent appeared confused and had an unsteady gait after falling.

Though not observing any apparent injury, the notes reported staff members

performed a neurological assessment and gave decedent medication "for

possible pain."

South Mountain's medical director, Dr. Karry, submitted an affidavit

during the course of the litigation. In his affidavit, Dr. Karry explained the day

following decedent's fall, nursing staff told him decedent complained of pain

and his left foot was externally rotated. Dr. Karry ordered decedent to be sent

A-1790-23 3 to Newark Beth Israel Medical Center for evaluation and any necessary

treatment. Because he went to the medical center on September 16, 2019, South

Mountain discharged decedent that day.

An x-ray at the medical center revealed decedent fractured his hip. Dr.

Lee performed a partial hip replacement on September 16, 2019. According to

an affidavit submitted by Dr. Lee, he "personally reviewed x-rays that confirmed

that [decedent] suffered from a displaced subcapital left-hip fracture, femoral

fracture." Based on his training and experience, Dr. Lee opined "within a

reasonable degree of medical probability . . . [decedent] suffered the hip fracture

from the fall that occurred on September 15, 2019."

South Mountain re-admitted decedent for rehabilitation after his hip

surgery. The facility discharged him on November 9, 2019. Decedent

subsequently lived with his family until his death in February 2023.2

In July 2020, decedent filed a lawsuit against defendants, alleging

negligence and violation of his rights under the New Jersey Nursing Home

Responsibilities and Rights of Residents Act (NHA or Act), N.J.S.A. 30:13-1 to

-17. In a three-count complaint, plaintiff asserted claims against defendants for

corporate negligence (count one), facility negligence (count two), and violation

2 Decedent's death was unrelated to his fall at South Mountain. A-1790-23 4 of the NHA (count three). After decedent's death, his son received permission

to substitute as plaintiff and pursued the claims against defendants. Defendants

filed an answer and the parties exchanged discovery.

According to a case management order extending discovery, the judge set

February 28, 2023 as the date for completion of all discovery. However, upon

agreement of counsel, the deposition of Dr. Carol White, plaintiff's expert, took

place about a month after the close of discovery. The day after her March 30,

2023 deposition, plaintiff's counsel submitted a supplemental expert report

offering Dr. White's opinion as to proximate cause.

Defendants moved to bar Dr. White's supplemental expert report. After

hearing argument, the judge entered an April 28, 2023 order barring the

supplemental expert report. Dr. White's supplemental expert report was the first

time plaintiff proffered a causation opinion regarding defendants' purported

negligence.

As the judge noted, Dr. White's supplemental expert report violated the

discovery deadline in the case management order. The judge found the

supplemental expert report was filed four-and-a-half months after the deadline

for submission of plaintiff's expert reports. Additionally, the judge explained

plaintiff failed to certify the information in the supplemental expert report was

A-1790-23 5 unavailable prior to the discovery deadline. In fact, based upon Dr. White's

deposition testimony, the judge concluded there was no new information

considered by Dr. White in issuing her supplemental expert report.

Further, the judge found it incredulous that Dr. White's supplemental

expert report was created and submitted to defense counsel within twenty-four

hours after completing her deposition. At no time prior to Dr. White's deposition

did plaintiff's counsel indicate an intent to submit a supplemental expert report

from Dr. White.

The judge also explained defense counsel deposed Dr. White based on the

information in her original expert report. The judge stated it was "not fair" to

defendants to proceed with a deposition when plaintiff knew Dr. White was

submitting a supplemental expert report. As the judge stated: "[T]he point of

taking a deposition is to nail down the witness to the scope of the testimony

available." Thus, the judge barred Dr. White's supplemental expert report,

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