Moran v. Caulkins

12 Mass. L. Rptr. 667
CourtMassachusetts Superior Court
DecidedDecember 19, 2000
DocketNo. 971310
StatusPublished
Cited by4 cases

This text of 12 Mass. L. Rptr. 667 (Moran v. Caulkins) is published on Counsel Stack Legal Research, covering Massachusetts Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Moran v. Caulkins, 12 Mass. L. Rptr. 667 (Mass. Ct. App. 2000).

Opinion

Butler, J.

Presently before the court is a motion by defendant Robert M. Caulkins, M.D. (“defendant” or “Caulkins”) for summary judgment in this action and plaintiff Linda Moran’s (“plaintiff’) cross motion for partial summary judgment, filed pursuant to Rule 56(c) of the Massachusetts Rules of Civil Procedure (“Rule 56(c)”). For the reasons stated below, these motions are denied.

BACKGROUND

Defendant contends that the relief requested by plaintiff is barred by the Massachusetts Tort Claims Act, G.L.c. 258 (the “MTCA”) because, at the time he treated plaintiff, he was a public employee and thus immunized from tort liability. Plaintiffs cross motion asserts that the MTCA is no bar and that she is entitled to summary judgment with respect to liability. The undisputed facts relevant to this issue, occurring in 1994, are as follows.

This medical malpractice action was brought against Caulkins, an attending physician and Assistant Professor of Orthopedics and Physical Rehabilitation at the University of Massachusetts Medical Center (“UMMC”), based on his alleged eleventh-hour decision to perform a coral graft procedure instead of the scheduled bone graft without plaintiffs consent. Dr. Arthur M. Pappas, M.D. (“Pappas”), Chairman of Orthopedic Surgery, oversaw fifteen doctors, including Caulkins. Caulkins worked pursuant to an employment renewal contract with UMMC. This contract does not regulate the treatment of Caulkins’ patients.

Caulkins participated in the University of Massachusetts Group Practice Plan (“Group Practice”), where monies collected from patients were deposited into a Commonwealth of Massachusetts account and used for purposes established by the Trustees of the University. The Group Practice contributed to his salary based on his clinical duties, such as attending to clinic patients and providing emergency coverage. Caulkins was compensated by UMMC for teaching medical students and supervising residents. He participated in the Commonwealth of Massachusetts’ contributory retirement system and its group health and insurance plans. Only Caulkins did not see any private patients and maintained an office at UMCC.

No one controlled or directed Caulkins’ day to day activities. Pappas testified at a deposition held on January 27, 2000, that he did not exercise any control over the details of Caulkins’ treatment decisions, including the types of operations Caulkins chose to perform. Specifically, Pappas admitted that (1) no one directly supervised Caulkins’ treatment decisions; (2) Caulkins performed numerous surgeries without seeking his recommendation; (3) orthopedic doctors are able to ignore his recommendations in certain circumstances; and (4) Caulkins was authorized to perform any kind of grafting procedure on plaintiff without seeking Pappas’ advice or approval.

Similarly, Caulkins testified at his deposition,1 inter alia, that: (1) no one controlled or directed his day-today activities; (2) he did not meet regularly with anyone to discuss his job assignments or responsibilities; (3) he treated his patients as he “thought appropriate,” deciding which operations should be performed on which patients, subject only to subsequent peer reviews/discussions; (4) he was not required to seek anyone’s opinion before performing surgeries and did not seek one in the instant case; (5) he did not need to obtain anyone’s permission to perform the grafting [668]*668procedure performed on plaintiff nor was he required to report to anyone concerning this procedure.

DISCUSSION

Standard for Summary Judgment Motion

Summary judgment is appropriate when no material facts are in dispute and the moving party is entitled to judgment as a matter of law. Mass.R.Civ.P 56(c); see also Highland Ins. Co. v. Aerovox, Inc., 424 Mass. 226, 232 (1997). The oft-recited particulars are set out in Pederson v. Time, Inc., 404 Mass. 14 (1989), and Kourouvacilis v. General Motors Corp., 410 Mass. 706, 716 (1991). When reviewing a summary judgment record, the court credits facts in the light most favorable to the nonmoving party. Williams v. Hartman, 413 Mass. 398, 401 (1992).

Genuine Issue of Material Fact Exists as to Whether Caulkins is a Public Employee

Caulkins asserts that he is entitled to summary judgment on all counts of the complaint because he is a “public employee” immune from personal liability for his alleged negligence under the MTCA. That statute, G.L.c. 258, §2, makes the public employer, but not the public employee, liable for claims arising out of negligence. See Schenker v. Binns, 18 Mass.App.Ct. 404, 404 (1984) (MTCA “imposes liability on a public employer for a public employee’s negligent act performed within the scope of his employment and relieves the public employee from liability”). It provides, in pertinent part: “[pjublic employers shall be liable for injury or loss of property or personal injury or death caused by the negligent or wrongful act or omission of any public employee while acting within the scope of his office or employment, in the same manner and to the same extent as a private individual under like circumstances . . .” G.L.c. 258, §2.

When determining “public employee” status, the dispositive question is whether a person is subject to the direction and control of a public employer. Smith v. Steinberg, 395 Mass. 666, 669 (1985); see also Kelley v. Rossi, 395 Mass. 659 (1985) (summary judgment was not appropriate because factual issues concerning the degree of direction and control over the physician exercised by the public employer remained). The Massachusetts Supreme Judicial Court instructs that physicians, in most circumstances, act as independent contractors, not public employees; the key question is whether a public employer controls the details of a physician’s day to day activities and the treatment of his patients. See Williams v. Hartman, 413 Mass. 398, 400-01 (1992) (“[a] physician is not necessarily a public employee simply because a public entity pays his or her salary, provides a retirement fund, or manages a vacation schedule”); Kelley, 395 Mass. at 662 (”[T]he very nature of a physician’s function tends to suggest that in most instances [the physician] will act as an independent contractor”). “Relevant considerations include whether the physician controls his own hours and work schedule, whether he determines which patients he will treat, and whether his compensation is fixed or based on productivity." Williams, 413 Mass. at 400-01; see also Hopper v. Callahan, 48 Mass. 621, 635 (1990).

Applying these standards to the record viewed in the light most favorable to plaintiff, there is a genuine issue of material fact as to whether Caulkins is a public employee. Plaintiff correctly does not contest the public employer status of the University of Massachusetts. See G.L.c. 258, §1 (public employer defined as including the Commonwealth and any “department, office, commission, committee, council, board, division, bureau, institution, agency, or authority thereof. . . which exercises direction and control over the public employee”); see also McNamara v. Honeyman, 406 Mass. 43, 47 (1989); Robinson v. Commonwealth, 32 Mass.App.Ct. 6, 9 (1992). However, the fact that the University is a “public employer” for purposes of the MTCA does not automatically establish that its employees are “public employees”; whether an individual is a public employee is a question of fact.

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12 Mass. L. Rptr. 667, Counsel Stack Legal Research, https://law.counselstack.com/opinion/moran-v-caulkins-masssuperct-2000.