Marquez Rivas v. Kern County Hospital Authority

District Court, E.D. California·Decided April 22, 2025·No. 1:24-cv-00859·Unknown

Opinion

CELINA MARQUEZ RIVAS, et al., ) Case No.: 1:24-cv-00859 JLT CDB ) Plaintiffs, ) ORDER GRANTING THE UNITED STATES’ ) MOTION TO DISMISS AND REMANDING v. ) ACTION TO KERN COUNTY SUPERIOR ) COURT KERN COUNTY HOSPITAL AUTHORITY, et ) al., ) ) (Doc. 4) ) Defendants. ) ) Celina Marquez Rivas and Juan Fernando Garcia seek to hold Defendants liable for the death of their newborn daughter, Casandra. (See generally Doc. 1-1.) After removing the case from state court and substituting itself as a defendant in place of Defendant Omni Family Health, the United States filed this motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(1). (Doc. 4.) For the reasons set forth below, the motion is GRANTED, Plaintiffs’ claims against the United States are DISMISSED, and this action is REMANDED to the Kern County Superior Court as to Plaintiffs’ remaining claims. /// /// /// /// A. Statutory Background As a general principle, the United States “may not be sued without its consent.” United States v. Mitchell, 463 U.S. 206, 212 (1983). However, subject to certain exceptions, the Federal Tort Claims Act “provides a waiver of the United States government’s sovereign immunity for tort claims arising out of the conduct of government employees acting within the scope of their employment.” Adams v. United States, 420 F.3d 1049, 1051 (9th Cir. 2005) (citing 28 U.S.C. § 1346(b)(1)); see 28 U.S.C. §§ 2671, 2680. Under the FTCA’s “exclusive remedies provision, a plaintiff generally cannot sue an employee where the FTCA would allow him to sue the United States instead.” Simmons v. Himmelreich, 578 U.S. 621, 627-28 (2016) (citing 28 U.S.C. § 2679(b)(1)); see also Hui v. Castaneda, 559 U.S. 799, 806 (2010) (“The Westfall Act amended the FTCA to make its remedy against the United States the exclusive remedy for most claims against Government employees arising out of their official conduct.”). Under the Federally Supported Health Centers Assistance Act, 42 U.S.C. § 233, “federally ‘deemed’ community health centers and their employees are immune from malpractice suits for acts or omissions that occur within the scope of their employment. Instead, such suits must be brought exclusively against the United States under the [FTCA].” Huynh v. Sutter Health, 2021 WL 2268889, at *1 (E.D. Cal. June 3, 2021); see 42 U.S.C. §§ 233(a), (g). “Upon certification that the defendant employee was acting within the scope of his employment at the time of the incident giving rise to the suit, the case must be removed” to the federal district court embracing the state action and the proceeding is treated as a FTCA action against the United States, who substitutes as the defendant in place of the federal employee. D.L. by & through Junio v. Vassilev, 858 F.3d 1242, 1244, 1248 (9th Cir. 2017) (citing 42 U.S.C. § 233(c)); 28 U.S.C. § 2679(d)(1); 28 C.F.R. § 15.4; see also Moreno v. United States, 2023 WL 4464237, at *2 (E.D. Cal. July 11, 2023) (“When such certification [under § 2679(d)(1) of the FTCA] is made, the individual employee is dismissed from the case and the United States is substituted as the defendant in place of the employee.”). Importantly, “[t]he suit is then governed by the FTCA and is subject to all of the FTCA’s exceptions for actions in which the Government has not waived sovereign immunity.” Moreno, 2023 WL 4464237, at *2 (citing Wuterich v. Murtha, 562 F.3d 375, 380 (D.C. Cir. 2009)). B. Factual and Procedural Background On November 14, 2022, Plaintiffs brought this medical malpractice action in the Superior Court of California, County of Kern, alleging that their newborn daughter, Casandra, died after being discharged from Kern Medical following her birth despite having high to high-intermediate risk predictors for bilirubin. (See Complaint, Doc. 1-1 at 5-6 ¶¶ 22-26.) The Complaint asserts causes of action for wrongful death, negligence, and negligent infliction of emotional distress against Kern County Hospital Authority, operating and known as Kern Medical; Emma Holt, M.D.; Chezhiyan Murugesan, M.D.; Vivette Williams, R.N.; Omni Family Health; Juan Lopez, M.D.; and Does 1-100. (See generally Complaint.) Plaintiffs allege that Dr. Holt, Dr. Murugesan, and Nurse Williams are employed, contracted, or otherwise associated with Kern Medical, and that Dr. Lopez is employed, contracted, or otherwise associated with Omni. (Id. at 4 ¶¶ 7-9, 11.) Citing the FSHCAA and Omni’s status as a deemed Public Health Service employee, the United States timely removed the action to this Court and substituted itself as a defendant in place of Omni. (See Docs. 1, 1-2, 3.)1 Having established that Plaintiffs’ claims against Omni are treated as FTCA claims against the United States, 42 U.S.C. § 233(c), the United States now moves to dismiss the claims based on the FTCA’s independent contractor exception. (Doc. 4.) Plaintiffs filed an opposition (Doc. 12), to which the United States replied. (Doc. 13.)

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