Lucas v. Medical Facilities of America, Inc.

74 Va. Cir. 206, 2007 Va. Cir. LEXIS 180
CourtRoanoke County Circuit Court
DecidedSeptember 28, 2007
DocketCase No. CL02001078
StatusPublished

This text of 74 Va. Cir. 206 (Lucas v. Medical Facilities of America, Inc.) is published on Counsel Stack Legal Research, covering Roanoke County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lucas v. Medical Facilities of America, Inc., 74 Va. Cir. 206, 2007 Va. Cir. LEXIS 180 (Va. Super. Ct. 2007).

Opinion

By Judge Clifford r. Weckstein

Geraldine M. Lucas, John J. Lucas’s widow and the administrator of his estate, asserts in this suit that Mr. Lucas’s death was caused by negligence of his doctors or of personnel at Salem Health and Rehabilitation Center (“Salem Health”) or of both. The threshold question is whether her claim against Salem Health will be evaluated on its merits or summarily thrown out of court.

Salem Health’s owners, two limited partnerships, contend that the claim against the nursing home must be dismissed because, under the Revised Uniform Partnership Act (RUPA),1 “a partnership is an entity distinct from its partners and a partnership is to be sued in the name of the partnership.” Brief [207]*207Filed in Support of Defendant Medical Facilities of America, Inc.’s Motion for Summary Judgment and Defendants Medical Facilities of America I and Medical Facilities of America II, Limited Partnership’s Demurrer and Plea in Bar, at 4 (hereafter, Defendants’ Brief). Though the RUPA is the law in 43 states including Virginia,2 this argument has been made in only a few reported cases3 (never, apparently, in Virginia), and accepted only by the courts of Nevada. Richard Matthews, Jr., Inc. v. Vaughn, 91 Nev. 583, 540 P.2d 1062 (1975) (limited partnership can only be sued in partnership name). Applying familiar principles of statutory construction, I hold that the RUPA neither requires the administrator to sue each limited partnership in its own name nor otherwise bars her from proceeding with the claim against the Salem Health.

1. Facts

On this threshold question, there are no material facts in dispute. For present purposes, the parties agree that, at all relevant times, Salem Health was owned by two limited partnerships, Medical Facilities of America I, Limited Partnership and Medical Facilities of America II, Limited Partnership (“the limited partnerships”). Medical Facilities of America, Inc. (“MFA, Inc.”) was the general partner in each of the limited partnerships. The administrator filed this wrongful death suit just before the expiration of the two-year statute of limitations. See Va. Code § 8.01-244(B) (wrongful death actions “shall be brought by the personal representative of the decedent within two years after the death of the injured person”); Riddett v. Virginia Elec. & Power Co., 255 Va. 23, 28, 495 S.E.2d 819 (1998) (the limitation period for bringing wrongful death action is a substantive part of the action). MFA, Inc., was named as a defendant, and was served with process. Neither of the limited [208]*208partnerships was named as a defendant. The initial motion for judgment identified MFA, Inc., as the entity doing business as Salem Health and Rehabilitation Center. The administrator has twice amended her pleadings. She named the limited partnerships as defendants, but did not do so within two years of Mr. Lucas’s death.

II. Posture of the Case

The only issue addressed in this opinion letter is whether the administrator can proceed with her claims against the owners and operators of Salem Health. The allegations against Mr. Lucas’s physicians are not at issue here; references in this opinion letter to “defendants” are only to entities associated with Salem Health.

The case is before the court upon the administrator’s second amended motion for judgment, upon a demurrer and a plea in bar filed by each of the limited partnerships, and upon a motion for summary judgment filed by MFA, Inc.

According to these defendants, it is not enough, under the RUPA, to sue and serve a limited partnership’s general partner. Each limited partnership, in its own name, is an indispensable party, they argue, and failure to sue the limited partnerships dooms consideration of the merits of the claim against Salem Health. “Moreover,” the defendants say, “a partner cannot be held liable for debts of the partnership unless a judgment is first obtained against the partnership and cannot be collected.” Defendants’ Brief, at 4.

Counsel are thoroughly familiar with the rules that I must follow when ruling on demurrers,4 special pleas,5 and motions for summary judgment.6I will not further lengthen this already-long opinion letter by repeating those rules here. Counsel also are aware that the Supreme Court of Virginia discourages trial judges from granting motions that short circuit the legal [209]*209process, deprive a litigant of his or her day in couit, and deprive the Supreme Court of an opportunity to review a thoroughly developed record on appeal. Seyfarth, Shaw, Fairweather & Geraldson v. Lake Fairfax Seven, Ltd., 253 Va. 93, 95, 480 S.E.2d 471 (1997) (internal citations omitted).

I begin my analysis at the logical starting place, a discussion of the statutory scheme and the common law.

III. Analysis

A. The Common Law and the Partnership Acts

Virginia has adopted both the Revised Uniform Limited Partnership Act, Va. Code § 50-73.1 et seq. (“Limited Partnership Act”) and the RUPA. In situations not covered by the Limited Partnership Act, the RUPA governs. Va. Code § 50-73.75; see IMWA Equities IX Co. v. WBC Assoc., Ltd. Partnership, 961 F.2d 480, 482 (4th Cir. 1992). And, in turn, “the principles of law and equity” supplement the RUPA, “[ujnless displaced by particular provisions” of the RUPA.” Va. Code § 50-73.82; see McCormick v. Romans, 214 Va. 144, 147, 198 S.E.2d 651 (1973); Hoover’s Ex’rs v. Bowers, Hoover & Co., 146 Va. 84, 135 S.E. 698 (1926). We turn, then, to those principles of law and equity, to the common law. “The common law of England, insofar as it is not repugnant to the principles of the Bill of Rights and Constitution ofthis Commonwealth, shall continue in full force within the same, and be the rule of decision, except as altered by the General Assembly.” Va. Code § 1-200.

“At common law, a partnership could neither sue nor be sued in the firm name, because it was not recognized as a separate entity.” See McCormick, 214 Va. at 147 (Uniform Partnership Act does not change common law rules; partnership name need not be in caption of suit). The RUPA, in derogation of the common law, that is, partially altering or abolishing it, says that a partnership is “an entity distinct from its partners,” Va. Code § 50-73.87, one that “may sue and be sued in the name of the partnership.” Va. Code § 50-73.97. To say that a partnership may be sued in its own name is quite a different thing from saying that it must be sued in that name.

When the legislature adopts a statute that is in derogation of the common law, “only those parts of the common law directly altered by the statute are deemed to be changed.” Couplin v. Payne, 270 Va.

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74 Va. Cir. 206, 2007 Va. Cir. LEXIS 180, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lucas-v-medical-facilities-of-america-inc-vaccroanokecty-2007.