Nathan Philipp v. Methodist Hospitals of Dallas D/B/A Methodist Dallas Medical Center

CourtCourt of Appeals of Texas
DecidedJuly 6, 2022
Docket05-21-00350-CV
StatusPublished

This text of Nathan Philipp v. Methodist Hospitals of Dallas D/B/A Methodist Dallas Medical Center (Nathan Philipp v. Methodist Hospitals of Dallas D/B/A Methodist Dallas Medical Center) 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
Nathan Philipp v. Methodist Hospitals of Dallas D/B/A Methodist Dallas Medical Center, (Tex. Ct. App. 2022).

Opinion

Affirmed and Opinion Filed July 6, 2022

In The Court of Appeals Fifth District of Texas at Dallas No. 05-21-00350-CV

NATHAN PHILIPP, Appellant V. METHODIST HOSPITALS OF DALLAS D/B/A METHODIST DALLAS MEDICAL CENTER, Appellee

On Appeal from the 14th Judicial District Court Dallas County, Texas Trial Court Cause No. DC-20-12429

MEMORANDUM OPINION Before Justices Myers, Osborne, and Nowell Opinion by Justice Myers This is an appeal challenging the trial court’s order granting appellee

Methodist Hospitals of Dallas d/b/a Methodist Dallas Medical Center’s

(Methodist’s) motion to dismiss with prejudice appellant Nathan Philipp’s

healthcare liability lawsuit. Philipp brings two issues. We affirm the trial court’s

order.

BACKGROUND

On September 3, 2020, appellant Philipp filed health care liability claims

against appellee Methodist, alleging defects in his care and treatment. Methodist

timely filed its original answer on September 28, 2020. Because Philipp’s claims against Methodist are health care liability claims, they are governed by Chapter 74

of the Texas Civil Practice and Remedies Code.

On January 27, 2021, Philipp served on Methodist an expert report and a

curriculum vitae from Barbara Sampley, R.N. On February 12, 2021, Methodist

timely filed its combined statutory objections to the expert report and curriculum

vitae, and a motion to dismiss Philipp’s suit for failure to comply with Chapter 74.

Philipp filed a motion for extension of time to file an expert report on March 15,

2021, and on March 23 Methodist filed an amended motion to dismiss. This filing

specifically noted that Philipp’s expert report was untimely under Chapter 74,

section 74.351, because it was filed after the expiration of the 120-day deadline.

On March 25, 2021, the trial court held a hearing on Methodist’s statutory

objections, its motion to dismiss, and Philipp’s motion for extension. During that

hearing, the trial court informed the parties it had signed an order on March 17, 2021,

sustaining Methodist’s objections and dismissing Philipp’s lawsuit. The order states

in part that “Plaintiff’s expert Barbara Sampley, R.N. does not meet the requirements

of an expert witness and that her report is wholly deficient, pursuant to Chapter 74

of the Texas Civil Practice and Remedy [sic] Code.” The order dismisses Philipp’s

claims against Methodist with prejudice. The court also denied Philipp’s motion for

extension on March 25, 2021, according to the court’s docket sheet.

On April 15, 2021, Philipp filed a motion for new trial, to which Methodist

replied in opposition on May 10, 2021. Methodist’s response stressed that the expert

–2– report of Barbara Sampley, R.N., was untimely under Chapter 74. Methodist’s

response included a calendar that counted each of the 120 days Philipp had to timely

file an expert report under Chapter 74 and demonstrated that he filed his expert report

after the expiration of the 120-day deadline. Philipp subsequently filed this appeal.

DISCUSSION

Philipp brings two issues, first arguing the trial court erred in denying his

motion to extend the time to file an expert report as allowed by section 74.351(c) of

the Texas Civil Practice and Remedies Code, and second, that the trial court erred in

finding Philipp’s expert report was not an objective good faith effort to provide an

expert report.

We review a trial court’s decision to grant or deny a motion to dismiss under

section 74.351 for an abuse of discretion. Am. Transitional Care Ctrs. of Tex., Inc.

v. Palacios, 46 S.W.3d 873, 875 (Tex. 2001); Broxterman v. Carson, 309 S.W.3d

154, 157 (Tex. App.—Dallas 2010, pet. denied). Under this standard, we defer to a

trial court’s factual determinations, but review de novo questions of law that involve

statutory interpretation and constitutional challenges. Stockton v. Offenbach, 336

S.W.3d 610, 615 (Tex. 2011). A trial court has no discretion in determining what

the law is or applying the law to the facts. Univ. of Tex. Med. Branch at Galveston

v. Callas, 497 S.W.3d 58, 62 (Tex. App.—Houston [14th Dist.] 2016, pet. denied)

(citing Walker v. Packer, 827 S.W.2d 833, 840 (Tex. 1992)). The trial court’s failure

to analyze or apply the law correctly is an abuse of discretion. Id.

–3– “To proceed with a health care liability claim, a claimant must comply with

the expert report requirement of the Texas Medical Liability Act.” Callas, 497

S.W.3d at 61 n.1 (citing Stockton, 336 S.W.3d at 614); see Sutker v. Simmons, No.

05-18-00698-CV, 2019 WL 3001034, at *3 (Tex. App.—Dallas July 10, 2019, pet.

denied) (mem. op.). Section 74.351, titled “Expert Report,” provides in part:

In a health care liability claim, a claimant shall, not later than the 120th day after the date each defendant’s original answer is filed, serve on that party or the party’s attorney one or more expert reports, with a curriculum vitae of each expert listed in the report for each physician or health care provider against whom a liability claim is asserted. The date for serving the report may be extended by written agreement of the affected parties. Each defendant physician or health care provider whose conduct is implicated in a report must file and serve any objection to the sufficiency of the report not later than the later of the 21st day after the date the report is served or the 21st day after the date the defendant’s answer is filed, failing which all objections are waived. TEX. CIV. PRAC. & REM. CODE § 74.351(a). Subsection (b) provides:

If, as to a defendant physician or health care provider, an expert report has not been served within the period specified by Subsection (a), the court, on the motion of the affected physician or health care provider, shall, subject to Subsection (c), enter an order that:

(1) awards to the affected physician or health care provider reasonable attorney’s fees and costs of court incurred by the physician or health care provider; and (2) dismisses the claim with respect to the physician or health care provider, with prejudice to the refiling of the claim.

Id. § 74.351(b). Subsection (c) reads as follows:

If an expert report has not been served within the 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. If the claimant does not receive notice of the court’s

–4– ruling granting the extension until after the applicable deadline has passed, then the 30-day extension shall run from the date the plaintiff first received the notice.

Id. § 74.351(c).

Section 74.351 presents “a statute-of-limitations-type deadline within which

expert reports must be served.” Ogletree v. Matthews, 262 S.W.3d 316, 319 (Tex.

2007); Sutker, 2019 WL 3001034, at *3. It requires the claimant to serve the expert

report and Curriculum Vitae (CV) on the party or the party’s attorney by the 120-

day deadline. TEX. CIV. PRAC. & REM. CODE § 74.351(a); Sutker, 2019 WL

3001034, at *3. “Although the deadline can lead to seemingly harsh results, strict

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Related

Ogletree v. Matthews
262 S.W.3d 316 (Texas Supreme Court, 2007)
Badiga v. Lopez
274 S.W.3d 681 (Texas Supreme Court, 2009)
Stockton Ex Rel. Stockton v. Offenbach
336 S.W.3d 610 (Texas Supreme Court, 2011)
American Transitional Care Centers of Texas, Inc. v. Palacios
46 S.W.3d 873 (Texas Supreme Court, 2001)
BROXTERMAN v. Carson
309 S.W.3d 154 (Court of Appeals of Texas, 2010)
Walker v. Packer
827 S.W.2d 833 (Texas Supreme Court, 1992)
Zanchi v. Lane
408 S.W.3d 373 (Texas Supreme Court, 2013)

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