McDonald v. Washington County Hospital Ass'n

54 Pa. D. & C.4th 324, 2001 Pa. Dist. & Cnty. Dec. LEXIS 394
CourtPennsylvania Court of Common Pleas, Franklin County
DecidedFebruary 27, 2001
Docketno. A.D. 1998-475
StatusPublished

This text of 54 Pa. D. & C.4th 324 (McDonald v. Washington County Hospital Ass'n) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Franklin County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McDonald v. Washington County Hospital Ass'n, 54 Pa. D. & C.4th 324, 2001 Pa. Dist. & Cnty. Dec. LEXIS 394 (Pa. Super. Ct. 2001).

Opinion

HERMAN, J.,

INTRODUCTION

Before the court are preliminary objections filed by defendant Washington County Hospital to the complaint [326]*326filed by the plaintiff in this action alleging medical malpractice in the death of plaintiff’s decedent. The two objections are Pennsylvania’s lack of personal jurisdiction over the defendant and the insufficiency of the complaint.1

DISCUSSION

Jurisdiction

Under the due process clause of the Fourteenth Amendment to the United States Constitution, there are two grounds for a state to exercise personal jurisdiction over a nonresident defendant. The first, general jurisdiction, occurs where the defendant maintains continuous and systematic contacts with the forum state. Burger King Corp. v. Rudzewicz, 471 U.S. 462, 105 S.Ct. 2174, 85 L.Ed.2d 528 (1985); Kubik v. Letteri, 532 Pa. 10, 614 A.2d 1110 (1992). The defendant must have certain minimum contacts with the forum state such that its exercise of jurisdiction will not offend traditional notions of fair play and substantial justice. International Shoe Co. v. Washington, 326 U.S. 310, 66 S.Ct. 154, 90 L.Ed.2d 95 (1945); Insulations Inc. v. Journeymen Welding & Fab, 700 A.2d 530 (Pa. Super. 1997). Minimum contacts can be found where a defendant’s conduct and his connection with the forum state are such that it was reasonable for him to anticipate being called to defend himself there. Random, fortuitous and attenuated contacts are not enough, nor is unilateral activity in the forum by others [327]*327who claim some relationship with the defendant. Instead the defendant must have purposefully directed his activities to the forum state and its residents and conducted himself in a manner indicating he has availed himself of the privileges and benefits of that forum’s laws such that he should be subject to those laws. World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 100 S.Ct. 559, 62 L.Ed.2d 490 (1980); Burger King; Surgical Laser Technologies v. C.R. Bard Inc., 921 F. Supp. 281, 285 (E.D. Pa. 1996); Kubik.

A second basis for jurisdiction can be found in the specific conduct of the defendant which gave rise to the litigation (specific jurisdiction). Helicopteros v. Nacionales de Colombia v. Hall, 466 U.S. 408, 104 S.Ct. 1868, 80 L.Ed.2d 404 (1984). Specific personal jurisdiction has a more narrow scope than general jurisdiction, and focuses on the particular actions of the defendant which gave rise to the underlying cause of action. Hall-Woolford Tank Co. Inc. v. R.F. Kilns Inc., 698 A.2d 80 (Pa. Super. 1997). Specific jurisdiction may arise where the defendant’s contacts with the forum state are infrequent but are nevertheless related to the plaintiff’s claim.

Pennsylvania’s long-arm statute allows Pennsylvania courts to exercise personal jurisdiction over a corporation where it carries on “continuous and systematic part of its general business within this Commonwealth.” 42 Pa.C.S. §5301(a)(2)(iii). Under section 5322(b), jurisdiction may be exercised over a nonresident defendant “to the fullest extent allowed under the Constitution of the United States and may be based on the most minimum contacts with this Commonwealth allowed under [328]*328the Constitution of the United States.” A Pennsylvania court may exercise personal jurisdiction over a nonresident defendant based on the relationship between the defendant, the Commonwealth and the facts underlying the litigation, and also where the defendant has sufficient minimum contacts to satisfy federal due process requirements. In other words, even where jurisdiction cannot be based on a relationship between the defendant, the forum state and the particular conduct or activities underlying the cause of action, Pennsylvania courts may exercise jurisdiction if the defendant’s general activities within the Commonwealth are sufficiently “continuous and substantial” under federal constitutional standards. Remick v. Manfredy, 52 F. Supp. 452 (E.D. Pa. 1999).

It is well-established that the court must consider preliminary objections, including a challenge to jurisdiction, in the light most favorable to the non-moving party. Once the defendant comes forward with support for its jurisdictional objection, the burden shifts to the plaintiff to show by a preponderance of the evidence there is statutory and constitutional support for the forum state’s exercise of jurisdiction. Snider v. Howard S. Slatkin Inc., 105 F.Supp.2d 428 (E.D. Pa. 2000); Hall-Woolford. The plaintiff must show prima facie evidence of jurisdiction by establishing with reasonable particularity sufficient contacts between the defendant and the forum state. Snider; Crompton v. Park Ward Motors Inc., 299 Pa. Super. 40, 445 A.2d 137 (1982).

The hospital argues there is no basis for Pennsylvania to exercise general or specific jurisdiction because the complaint contains no facts showing it has continuous [329]*329and systematic contacts with the Commonwealth sufficient to establish minimum contacts, specifically, that it has not purposefully availed itself of the Pennsylvania market or directed its business activities toward Pennsylvania residents. The hospital points to the statements in the affidavit of Nelson Tillou, Washington County Hospital director of risk management, dated August 2, 2000, attached as exhibit A to the hospital’s preliminary objections that the hospital (1) is not incorporated in Pennsylvania, (2) is not qualified as a foreign corporation under Pennsylvania law, (3) is a Maryland corporation with its offices and principal place of business in Maryland, (4) is located in Maryland and (5) all treatment of the plaintiff’s decedent by the hospital staff occurred in Maryland. The plaintiff does not dispute these statements of fact. The hospital argues this court cannot exercise specific jurisdiction because the complaint does not aver the cause of action arose from the hospital’s actions in Pennsylvania and the plaintiff failed to plead the hospital purposefully sought to attract Pennsylvania consumers to its facility.

The plaintiff orally argued that Pennsylvania has jurisdiction over the hospital because of its geographic proximity to the state border (6 miles, a fact not in the record) and based on its continuous solicitation of patients from Pennsylvania by three methods.2 One is the [330]*330hospital’s grant of admitting privileges to physicians, including the physicians named as defendants, who are licensed to practice in Pennsylvania and maintain offices in the Commonwealth.

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Related

International Shoe Co. v. Washington
326 U.S. 310 (Supreme Court, 1945)
World-Wide Volkswagen Corp. v. Woodson
444 U.S. 286 (Supreme Court, 1980)
Helicopteros Nacionales De Colombia, S. A. v. Hall
466 U.S. 408 (Supreme Court, 1984)
Burger King Corp. v. Rudzewicz
471 U.S. 462 (Supreme Court, 1985)
Skinner Mfg. Co. v. General Foods Sales Co.
52 F. Supp. 432 (D. Nebraska, 1943)
Surgical Laser Technologies, Inc. v. C.R. Bard, Inc.
921 F. Supp. 281 (E.D. Pennsylvania, 1996)
Crompton v. Park Ward Motors, Inc.
445 A.2d 137 (Superior Court of Pennsylvania, 1982)
Ambrose v. Cross Creek Condominiums
602 A.2d 864 (Superior Court of Pennsylvania, 1992)
Snider v. Howard S. Slatkin, Inc.
105 F. Supp. 2d 428 (E.D. Pennsylvania, 2000)
Pike County Hotels Corp. v. Kiefer
396 A.2d 677 (Superior Court of Pennsylvania, 1978)
Burnside v. Abbott Laboratories
505 A.2d 973 (Supreme Court of Pennsylvania, 1985)
Laffey v. Lehigh Valley Dairy Cooperative
390 A.2d 238 (Superior Court of Pennsylvania, 1978)
Holt Hauling & Warehousing Systems, Inc. v. Aronow Roofing Co.
454 A.2d 1131 (Superior Court of Pennsylvania, 1983)
Kubik v. Letteri
614 A.2d 1110 (Supreme Court of Pennsylvania, 1992)
Hall-Woolford Tank Co. v. R.F. Kilns, Inc.
698 A.2d 80 (Supreme Court of Pennsylvania, 1997)
Insulations, Inc. v. Journeymen Welding & Fab
700 A.2d 530 (Superior Court of Pennsylvania, 1997)

Cite This Page — Counsel Stack

Bluebook (online)
54 Pa. D. & C.4th 324, 2001 Pa. Dist. & Cnty. Dec. LEXIS 394, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcdonald-v-washington-county-hospital-assn-pactcomplfrankl-2001.