Maldonado v. GeneDx

2024 COA 121
CourtColorado Court of Appeals
DecidedNovember 21, 2024
Docket23CA2092
StatusPublished
Cited by1 cases

This text of 2024 COA 121 (Maldonado v. GeneDx) is published on Counsel Stack Legal Research, covering Colorado Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Maldonado v. GeneDx, 2024 COA 121 (Colo. Ct. App. 2024).

Opinion

The summaries of the Colorado Court of Appeals published opinions constitute no part of the opinion of the division but have been prepared by the division for the convenience of the reader. The summaries may not be cited or relied upon as they are not the official language of the division. Any discrepancy between the language in the summary and in the opinion should be resolved in favor of the language in the opinion.

SUMMARY November 21, 2024

2024COA121

No. 23CA2092, Maldonado v. GeneDx — Health and Welfare — Health Care Availability Act — Limitation of Actions — Genetic Testing and Counseling

A division of the court of appeals interprets for the first time

section 13-64-502(1), C.R.S. 2024, holding that the parents alleged

a plausible claim for relief against medical professionals and health

care institutions for damages arising from allegedly negligent

genetic testing and counseling that could have prevented or avoided

the birth of twins with a medical disorder if the professionals and

institutions had exercised the ordinary standard of care. As a

result, the division reverses the district court’s dismissal of the

parents’ claims under C.R.C.P. 12(b)(5). COLORADO COURT OF APPEALS 2024COA121

Court of Appeals No. 23CA2092 City and County of Denver District Court No. 23CV31908 Honorable Martin F. Egelhoff, Judge

Secily Maldonado, individually, and as next friends, natural parents, and guardians of their son JAC, a minor, and their daughter JMC, a minor child, John Anthony Carcanaques, individually, and as next friends, natural parents, and guardians of their son JAC, a minor, and their daughter JMC, a minor child, J.A.C., individually by and through their guardians and custodians Secily Maldonado and John Anthony Carcanaques, and J.M.C., individually by and through their guardians and custodians Secily Maldonado and John Anthony Carcanaques,

Plaintiffs-Appellants,

v.

GeneDx, Inc., a New Jersey corporation; GeneDx, LLC; a Non-Maryland limited liability company; Katelyn Beattie, MSG, CGC; Amanda Lindy, FACMG, PhD; Children’s Hospital of Colorado, a Colorado nonprofit corporation; Alison Ballard, RN, CPNP; Melissa Gibbons, MS, Genetic Counselor; Lisa McCown, MS, Genetic Counseling Graduate Student; and University of Colorado Hospital Authority located at Anschutz Campus,

Defendants-Appellees.

JUDGMENT AFFIRMED IN PART, REVERSED IN PART, AND CASE REMANDED WITH DIRECTIONS

Division II Opinion by JUDGE JOHNSON Fox and Schock, JJ., concur

Announced November 21, 2024

Chalat Hatten & Banker, PC, James H. Chalat, Evan P. Banker, Denver, Colorado; Purvis Thompson, LLP, John A. Purvis, Michael J. Thompson, Boulder, Colorado, for Plaintiff-Appellants Taylor Anderson LLP, John T. Osgood, James D. Murdock, II, Benjamin Wright, Christine L. Atwood, Denver, Colorado, for Defendants-Appellees GeneDx, Inc.; GeneDx, LLC; Katelyn Beattie; and Amanda Lindy

Hall Booth Smith, P.C., Elizabeth C. Moran, Rodrigo Lugo, Greenwood Village, Colorado; Hall Booth Smith, P.C., Ryan M. Donihue, Atlanta, Georgia for Defendant-Appellee Children’s Hospital of Colorado

Conklin Cardone & Rutberg, PC, John Conklin, Deann Zenisek, Denver, Colorado for Defendants-Appellees Alison Ballard, Melissa Gibbons, Lisa McCown, and University of Colorado Hospital Authority ¶1 In 1988, the General Assembly enacted the Health Care

Availability Act (HCAA), effective July 1, 1988. See §§ 13-64-101 to

-503, C.R.S. 2024. Currently, and as originally passed, section 13-

64-502(1), C.R.S. 2024, limits the scope of liability in certain

negligence actions against health care professionals. There is,

however, an exception. As originally passed, the exception

authorized lawsuits for “injury” that could have been “prevented or

avoided” had the health care professional acted consistent with the

ordinary standard of care. § 13-64-502, C.R.S. 1988 (repealed

1989).

¶2 Approximately five months after the HCAA’s enactment, our

supreme court decided Lininger v. Eisenbaum, 764 P.2d 1202, 1204

(Colo. 1988). The case recognized a common law negligence action

seeking damages against a doctor who provided the parents with

medical advice that their first child’s eye condition resulting in

blindness was not genetic, yet their second child developed the

same eye condition as his sibling.

¶3 Following Lininger, the General Assembly amended section 13-

64-502(1), effective July 1, 1989, by broadening the statutory bar

against negligence actions to preclude claims for “damage or injury”

1 arising from “genetic counseling and screening” but also expanding

the exception to permit lawsuits involving “damage or injury”

resulting from a “genetic disease or disorder” that could have been

prevented or avoided if the ordinary standard of care had been met.

Ch. 135, sec. 4, § 13-64-502(1), 1989 Colo. Sess. Laws 763.

¶4 Since its enactment, no case has interpreted section 13-64-

502(1). Given the timing of this provision’s amendment in 1989, as

well as the plain language of the statute, it is reasonable to

interpret the provision consistent with Lininger’s holding.

Specifically, we give effect to the term “damage” in the statute to

permit a claim for economic damages for a child’s medical expenses

or other extraordinary expenses resulting from a health care

professional’s alleged negligent genetic counseling or screening.

¶5 In this case, the parents brought an action against medical

professionals alleging that negligent genetic testing and counseling

led them to believe their twins would not be — but were in fact —

affected by a severe medical disorder. The district court dismissed

the parents’ claims under C.R.C.P. 12(b)(5), reasoning that the

lawsuit did not fall under section 13-64-502(1)’s exception. But the

parents’ claims do fall squarely under that exception, so we reverse

2 and reinstate the complaint as to those claims. As to the children’s

claims against the medical professionals, however, we conclude that

the district court properly dismissed them under Lininger. And we

decline to address damages because the issue was not resolved

below. Therefore, we reverse in part, affirm in part, and remand the

case to the district court for further proceedings consistent with

this opinion.

I. Background

¶6 Plaintiffs Secily Maldonado (Maldonado) and John Anthony

Carcanaques (Carcanaques) (collectively the parents) brought this

action on behalf of themselves and on behalf of their twins,

plaintiffs J.A.C. and J.M.C. (collectively the children), who also

asserted claims on behalf of themselves. The complaint alleged that

defendants — who include the Children’s Hospital of Colorado, the

University of Colorado Hospital Authority, Alison Ballard (Ballard),

Melissa Gibbons (Gibbons), and Lisa McCown (McCown)

(collectively, Hospital Defendants) as well as GeneDx, Inc.; GeneDx,

LLC; Katelyn Beattie (Beattie); and Amanda Lindy (Lindy)

(collectively GeneDx Defendants) — negligently misrepresented to

Maldonado that she was not a genetic carrier of Duchenne

3 Muscular Dystrophy (DMD) and that the parents relied on that

information and Maldonado ultimately gave birth to J.A.C. (who has

developed DMD) and J.M.C. (who is a carrier of DMD).

¶7 Based on the allegations in the complaint, DMD is an

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Maldonado v. GeneDx
2024 COA 121 (Colorado Court of Appeals, 2024)

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