Kim v. HCA Healthcare Inc

CourtDistrict Court, N.D. Texas
DecidedMarch 7, 2021
Docket3:20-cv-00154
StatusUnknown

This text of Kim v. HCA Healthcare Inc (Kim v. HCA Healthcare Inc) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kim v. HCA Healthcare Inc, (N.D. Tex. 2021).

Opinion

United States District Court NORTHERN DISTRICT OF TEXAS DALLAS DIVISION VICKIE KIM § : CIVIL ACTION NO. 3:20-CV-00154-S HCA HEALTHCARE, INC.; GREEN OAKS HOSPITAL SUBSIDIARY, L.P. § D/B/A MEDICAL CITY GREEN OAKS 8 HOSPITAL; AND JOEL HOLINDER § MLD. P.A. § MEMORANDUM OPINION AND ORDER This Order addresses: (1) Joel Holiner, M.D., P.A.’s Motion to Dismiss and Brief in Support of Motion to Dismiss (“Holiner Motion to Dismiss”) [ECF No. 13]; (2) HCA Healthcare Inc.’s Motion to Dismiss Plaintiff's Complaint (‘HCA Motion to Dismiss”) [ECF No. 16]; and (3) Defendant Medical City Green Oaks Hospital’s Motion to Dismiss Plaintiff's Original Complaint and Brief in Support (“Hospital Motion to Dismiss” ) [ECF No. 20] (altogether, “Motions to Dismiss”). Plaintiff asserts multiple Texas state law claims, including negligence, gross negligence, false imprisonment, civil conspiracy, violations of the Texas Health and Safety Code, and violations of the Texas Deceptive Trade Practices Act. See Compl. Counts II-[X. Plaintiff also asserts one federal cause of action—a Rehabilitation Act claim. See Compl. Count I. The Fifth Circuit has not addressed the application of the Rehabilitation Act to medical treatment. However, every circuit court that has taken up the issue has determined that a medical treatment decision cannot form the basis for a Rehabilitation Act claim. This Court, therefore, declines to expand the scope of the Rehabilitation Act beyond what has been recognized by the Fifth Circuit and all other circuit courts. As Plaintiff has not stated a federal claim upon which relief can be granted, as set

forth below, the Court GRANTS the Motions to Dismiss as to Plaintiff s Rehabilitation Act claim, GRANTS Plaintiff leave to replead her Rehabilitation Act claim, and ABATES Plaintiff's state- law claims. I. BACKGROUND Plaintiff Vickie Kim (“Plaintiff”) sought mental health treatment from Defendant Joel A. Holiner, M.D., P.A. (“Holiner’) in 2011 for anxiety, obsessive-compulsive disorder, and postpartum depression. See id. J] 18-19. Holiner is employed by Defendant Green Oaks Hospital Subsidiary, L.P. d/b/a Medical City Green Oaks Hospital (“Hospital”), a mental health facility owned and operated by HCA Healthcare, Inc. (“HCA”) (together with Holiner and Hospital, “Defendants”). See id. JJ 10-13. According to the Complaint, Plaintiff arrived at the Hospital and requested therapy at approximately 10:00 p.m. on January 24, 2018. See id. | 22-23. The Hospital’s staff took Plaintiff's statement, conducted a urine test, strip-searched Plaintiff, confiscated her shoes, and requested her billing information. See id. [J 24-25. Hospital staff then informed Plaintiff that she was being admitted into inpatient care. See id. 40. Plaintiff alleges that she told staff that she could not stay at the Hospital and did not want inpatient treatment. See id. 9] 26-29. Hospital staff allegedly falsified Plaintiff's medical records to indicate Plaintiff was suicidal and “intimidated and forced [Plaintiff] into a voluntary commitment.” /d. J§ 41, 44. On January 30, 2018, after seeing Holiner, Plaintiff was released. See id. § 47. Plaintiff does not provide any additional details regarding her alleged confinement at the Hospital, her visit with Holiner, or the circumstances surrounding her release. I. LEGAL STANDARD To defeat a motion to dismiss filed pursuant to Federal Rule of Civil Procedure 12(b)(6), a plaintiff must plead “enough facts to state a claim to relief that is plausible on its face.” Bell Atl.

Corp. v. Twombly, 550 U.S. 544, 570 (2007); Reliable Consultants, Inc. v. Earle, 517 F.3d 738, 742 (Sth Cir. 2008). To meet this “facial plausibility” standard, a plaintiff must plead “factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). Plausibility does not require probability, but a plaintiff must establish “more than a sheer possibility that a defendant has acted unlawfully.” Jd. The court must accept well-pleaded facts as true and view them in the light most favorable to the plaintiff. Sonnier v. State Farm Mut. Auto. Ins., 509 F.3d 673, 675 (Sth Cir. 2007). The ultimate question is whether the Complaint states a valid claim when viewed in the light most favorable to the plaintiff. Great Plains Tr. Co. v. Morgan Stanley Dean Witter & Co., 313 F.3d 305, 312 (5th Cir. 2002). At the motion to dismiss stage, the court does not evaluate the plaintiff's likelihood of success. It only determines whether the plaintiff has stated a claim upon which relief can be granted. Mann v. Adams Realty Co., 556 F.2d 288, 293 (5th Cir. 1977). Ti. ANALYSIS A. Rehabilitation Act To qualify for relief under the Rehabilitation Act, a plaintiff must demonstrate that: (1) she is an “individual with a disability under the Rehabilitation Act”; (2) who is “otherwise qualified” for participation in a program; (3) who is being “excluded from participation in, being denied the benefits of, or being subjected to discrimination under the program solely by reason of [ | her disability”; and (4) the program receives federal financial assistance. See Spann ex rel. Hopkins v. Word of Faith Christian Cir. Church, 589 F. Supp. 2d 759, 764 (S.D. Miss. 2008); see also Hileman vy. City of Dallas, 115 F.3d 352, 353 (Sth Cir. 1997); Chandler v. City of Dallas, 2 F.3d 1385, 1389-90 (5th Cir. 1993). Plaintiff has the burden of proof. See Chandler, 2 F.3d at 1390. Plaintiff does not cite, and the Court’s independent research has not revealed, any Fifth Circuit precedent applying the Rehabilitation Act to medical treatment decisions. Fifth Circuit

precedent addressing the Rehabilitation Act consists primarily of cases regarding discrimination in the employment, transportation, and education contexts. See, e.g., Pace v. Bogalusa Cnty. Sch. Bd., 403 F.3d 272, 275 (Sth Cir. 2005) (education); Zaylor v. City of Shreveport, 798 F.3d 276, 286 (Sth Cir. 2015) (sick leave); Frame v. City of Arlington, 657 F.3d 215, 225 (5th Cir. 2011) (sidewalk accessibility); Melton v. Dallas Area Rapid Transit, 391 F.3d 669, 675-76 (5th Cir. 2004) (public transportation); Lollar v. Baker, 196 F.3d 603, 609 (5th Cir. 1999) (employment). However, every circuit court that has addressed the issue has held that a medical treatment decision cannot form the basis of a Rehabilitation Act claim. See Burger v. Bloomberg, 418 F.3d 882, 882 (8th Cir.

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Bluebook (online)
Kim v. HCA Healthcare Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kim-v-hca-healthcare-inc-txnd-2021.