Michelle Elaine Grata M.D. v. Eva Hernandez, Individually and a/n.F of J.H., a Minor Child

CourtCourt of Appeals of Texas
DecidedApril 25, 2024
Docket01-23-00817-CV
StatusPublished

This text of Michelle Elaine Grata M.D. v. Eva Hernandez, Individually and a/n.F of J.H., a Minor Child (Michelle Elaine Grata M.D. v. Eva Hernandez, Individually and a/n.F of J.H., a Minor Child) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Michelle Elaine Grata M.D. v. Eva Hernandez, Individually and a/n.F of J.H., a Minor Child, (Tex. Ct. App. 2024).

Opinion

Opinion issued April 25, 2024

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-23-00817-CV ——————————— MICHELLE ELAINE GRATA, M.D., Appellant V. EVA HERNANDEZ, INDIVIDUALLY AND AS NEXT FRIEND OF J.H., A MINOR CHILD, Appellee

On Appeal from the 11th District Court Harris County, Texas Trial Court Case No. 2021-47717

MEMORANDUM OPINION

This is an accelerated interlocutory appeal from the denial of a motion to

dismiss for failure to comply with the expert-report requirements imposed by the

Texas Medical Liability Act. On appeal, Michelle Elaine Grata, M.D., contends that

the trial court had no choice but to grant her motion to dismiss after the plaintiff did not serve a curative expert report within the 30-day deadline to do so. In the

alternative, Grata maintains that the trial court erred in not granting her motion to

dismiss because the expert report does not adequately establish causation and

because the expert is unqualified to opine on the standard of care or its breach.

We affirm.

BACKGROUND

Eva Hernandez, individually and on behalf of her infant son, sued Dr. Grata

and several other defendants alleging that their negligence during labor and delivery

caused her newborn son to suffer a severe, permanent brain injury. Grata is an

anesthesiologist who administered an epidural anesthetic during labor. In this appeal,

Hernandez’s medical malpractice claim against Grata is the only one before us.

As required when a health care liability claim is involved, Hernandez timely

served Grata with an expert report made by Robert D. Eden, M.D. In his capacity as

a board-certified obstetrician-gynecologist and maternal fetal medicine specialist,

Eden opined that Grata breached the accepted standard of care for an

anesthesiologist in three ways. First, Grata breached the standard of care by

administering an epidural anesthetic to Hernandez when the fetus was in distress.

Second, Grata breached the standard of care by initially misplacing the epidural.

Third, Grata breached the standard of care by failing to monitor the fetus via fetal

2 scalp electrode after successfully administering the epidural on the second try. Eden

opined that each of these breaches is a but-for cause of the infant’s brain injury.

Grata timely objected to Eden’s report on two grounds and sought dismissal

of Hernandez’s claim for failure to file an adequate expert report. She contended that

Eden’s causation opinion is conclusory because it does not identify what she in

particular, as opposed to the other defendants, did to cause the brain injury at issue

and is not grounded in specific facts. Grata further contended that Eden is not

qualified to opine on the accepted standard of care regarding an anesthesiologist.

The trial court held a hearing on Grata’s objections. At the conclusion of the

hearing, the trial court asked Hernandez’s lawyer if he wanted the court to rule or

give Hernandez a 30-day extension to file an amended or supplemental report.

Hernandez’s lawyer eventually replied, “I’ll take the 30 days.” When asked by a

lawyer representing one of the defendants whether the trial court had made “any

ruling in terms of what needs to be cured in that 30 days,” the court replied, “Nope.

30 days.” Consistent with its ruling from the bench, the trial court’s corresponding

written order granting the 30-day extension to file an amended or supplemental

report declared that it had not found the report deficient, stating: “The Court

withholds any ruling on the sufficiency of Plaintiff’s Chapter 74 Report at this time.”

Hernandez eventually served an amended version of Eden’s report on Grata.

But it is undisputed that she did not serve the new report by the 30-day deadline.

3 The trial court then held a second hearing, during which it did not rule. About

two weeks later, the trial court signed an order denying Grata’s motion to dismiss.

The trial court did not state the rationale for its ruling in its order or otherwise.

Grata appeals.

DISCUSSION

I. Was the trial court required to dismiss after Hernandez failed to timely file an expert report curing alleged deficiencies in the original report?

Grata contends that because a trial court may grant an extension to serve an

amended or supplemental expert report only if it finds the original one is deficient,

an order granting an extension constitutes a finding of deficiency as a matter of law.

From there, Grata reasons that if a plaintiff fails to timely serve the amended or

supplemental expert report, the trial court must dismiss the lawsuit for failure to

timely serve an expert report that satisfies the Texas Medical Liability Act.

A. Standard of review

This issue presents a question of statutory interpretation, which we review de

novo. Randol Mill Pharmacy v. Miller, 465 S.W.3d 612, 615 (Tex. 2015).

B. Applicable law

A claimant asserting a health care liability claim is required to serve an expert

report on each physician or health care provider against whom she asserts a claim

no later than 120 days after they file an answer. TEX. CIV. PRAC. & REM. CODE

§ 74.351(a). If the claimant does not timely serve a report, the trial court must

4 dismiss her claim on the motion of the physician or health care provider. Id.

§ 74.351(b).

The expert report must provide “a fair summary of the expert’s opinions as of

the date of the report regarding applicable standards of care, the manner in which

the care rendered by the physician or health care provider failed to meet the

standards, and the causal relationship between that failure and the injury, harm, or

damages claimed.” Id. § 74.351(r)(6). Of course, the report also must be made by

someone qualified to opine on these subjects in the case. See id. § 74.351(r)(5).

A physician or health care provider may object to the sufficiency of an expert

report within 21 days of the date of service or the date after which they file an answer.

Id. § 74.351(a). If they do not do so by this deadline, any objection is waived. Id.

If the trial court finds that an expert report is deficient, “the court may grant

one 30-day extension to the claimant in order to cure the deficiency.” Id. § 74.351(c).

The trial court must grant the extension if the deficiency is curable. See Scoresby v.

Santillan, 346 S.W.3d 546, 549 (Tex. 2011) (“The trial court should err on the side

of granting the additional time and must grant it if the deficiencies are curable.”).

C. Analysis

Grata is correct that a trial court may grant an extension to amend or

supplement an expert report if it finds the original one to be deficient. See TEX. CIV.

PRAC. & REM. CODE § 74.351(c) (“If an expert report has not been served within the

5 period specified by Subsection (a) because elements of the report are found deficient,

the court may grant one 30-day extension to the claimant in order to cure the

deficiency.”). As our Supreme Court has observed, absent an agreement of the

parties to extend the deadline for serving an expert report, a trial court may grant an

extension only to allow a claimant to cure a report’s deficiencies.

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Michelle Elaine Grata M.D. v. Eva Hernandez, Individually and a/n.F of J.H., a Minor Child, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michelle-elaine-grata-md-v-eva-hernandez-individually-and-anf-of-texapp-2024.