Pathlink of Texas, LLC v. Ashlee M. Balderrama and Alejandro J. Martinez

CourtCourt of Appeals of Texas
DecidedDecember 30, 2024
Docket08-24-00090-CV
StatusPublished

This text of Pathlink of Texas, LLC v. Ashlee M. Balderrama and Alejandro J. Martinez (Pathlink of Texas, LLC v. Ashlee M. Balderrama and Alejandro J. Martinez) 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
Pathlink of Texas, LLC v. Ashlee M. Balderrama and Alejandro J. Martinez, (Tex. Ct. App. 2024).

Opinion

COURT OF APPEALS EIGHTH DISTRICT OF TEXAS EL PASO, TEXAS

PATHLINK OF TEXAS, LLC, § No. 08-24-00090-CV

Appellant, § Appeal from the

v. § County Court at Law No. 3

ASHLEE M. BALDERRAMA and § of El Paso County, Texas ALEJANDRO J. MARTINEZ, § (TC# 2023DCV2379) Appellees.

OPINION

This is a companion to a case we recently decided: Tenet Hosps. Ltd. v. Balderrama,

No. 08-23-00263-CV, 2024 WL 3845451, (Tex. App.—El Paso Aug. 16, 2024, pet. filed). The

issue there was whether a hospital’s alleged missteps in discharging its professional or

administrative services attendant to an autopsy are “directly related to health care” when the

autopsy is performed on a person who expired while a patient in the hospital. That question is

relevant to whether the aggrieved patient (or the patient’s representatives) must file an expert

report. Tex. Civ. Prac. & Rem. Code Ann. § 74.351. We held that it was, and they did need to file

a report. In this appeal, the physician group that employs the pathologist who performed the

autopsy asks the same question, and for reasons expressed in the Tenet Hospital case, we give the

same answer. I. BACKGROUND1

Ashlee Balderrama and Alejandro Martinez are married and share three children. When

Ashlee was pregnant with their fourth child—a son, who they named Aiden—the family received

his devastating diagnosis of trisomy 18.2 The family understood Aiden’s condition to be terminal.

Ashlee gave birth to Aiden on April 12, 2023, at Providence Memorial Hospital by a caesarian

section. Aiden died a few hours later. At oral argument in Tenet Hosps. Ltd., the the Parents agreed

that during his brief life, Aiden was a patient at Providence Memorial Hospital.

When Ashlee’s doctor discussed performing an autopsy on Aiden, she “made it clear . . .

that she did not want an invasive autopsy or for Aiden to be cut in any way since all parties already

knew that Aiden died due to trisomy 18.” But Ashlee orally agreed to a non-invasive autopsy after

her doctor described it as limited to a visual examination and medical imaging. She later signed an

autopsy consent form in which she limited her consent to only a “non[-]invasive autopsy.” She

again confirmed with the nurse who co-signed the consent form that “the autopsy would not

involve any cutting.”

While at Aiden’s viewing about a week later, the Parents discovered an invasive autopsy

had been performed and some of Aiden’s organs were missing. They immediately called

Providence, where a patient safety officer told them that the invasive autopsy had been necessary

1 Because the question before us is whether the Parents have asserted a health care claim, the facts we recite are as alleged in the Parents’ petition. Lake Jackson Med. Spa, Ltd. v. Gaytan, 640 S.W.3d 830, 836 (Tex. 2022). Pathlink has not conceded these facts. 2 Trisomy 18, or Edwards syndrome, is a chromosomal disorder that causes severe growth and developmental delays. When a trisomy 18 diagnosis is present, most pregnancies end in miscarriage or stillbirth, and the survival rate for babies born with trisomy 18 is low. Cleveland Clinic, Edwards Syndrome (Trisomy 18), https://my.clevelandclinic.org/health/diseases/22172-edwards-syndrome (last visited June 25, 2024).

2 to “determine cause of death,” and Ashlee’s consent form has been “misinterpreted.” Providence

later returned Aiden’s remaining organs to the funeral home, where he was finally cremated.

The Parents sued Providence, asserting a negligence claim that sought mental anguish

damages. Later, the Parents amended their petition to add Pathhlink as a defendant. The Parents

alleged that the autopsy was performed by “Dr. Harry L. Wilson, a pathologist, who was an

employee, agent, or servant of Pathlink, a third party which contracted with Providence to provide

pathology services, including autopsies.” The amended petition alleges that Pathlink was

vicariously liable for the acts of its agents and employees who had the following duty:

[T]o exercise the degree of care that a reasonably prudent medical provider would use to avoid harm to others under the circumstances . . . including preventing Aiden’s autopsy, determining Aiden’s cause of death and verifying the existence and extent of Ms. Balderrama’s limited Consent Form, allowing for the return of Aiden’s bloody body in a manner presentable and suitable for return to his parents, and allowing for the return of Aiden’s body with his organs intact to allow for proper burial.

They claimed that Pathlink breached that duty by “a) Negligent mishandling of a human body;

b) Failing to prevent Aiden’s unauthorized autopsy and organ removal; and c) Keeping Aiden’s

organs until demand was made for them after their absence was noted.”

After Pathlink answered, the Parents moved for a preliminary determination of whether

their claims are health care liability claims under Chapter 74 (TMLA), arguing that they are not.

See Tex. Civ. Prac. & Rem. Code Ann. § 74.353(a) (“On motion of a claimant filed not later than

30 days after the date each defendant’s original answer is filed, a court may issue a preliminary

determination regarding whether a claim made by the claimant is a health care liability claim for

the purposes of [the expert-report requirement].”).3 Pathlink responded, arguing that the claims

3 Section 74.353 was added in part to remedy the harsh result when a plaintiff sues a health care provider and erroneously concludes that the claim is not a “health care liability claim” for the purposes of the Act's expert report requirement. See Judiciary & Civil Jurisprudence Committee, Bill Analysis, Tex. S.B. 232, 87th Leg., R.S. (2021)

3 are health care liability claims. After a hearing on the motion, the trial court granted the Parents’

motion, finding that their claims are not health care liability claims under the TMLA. Providence

brought this accelerated interlocutory appeal under § 74.353(d). See id. § 51.014(a)(15)

(permitting interlocutory appeal from order making a preliminary determination on a claim under

§ 74.353).

II. DISCUSSION

A. The TMLA and health care liability claims

In response to the “medical malpractice insurance crisis” of the 1970s, the Texas

Legislature enacted the Medical Liability and Insurance Improvement Act (MLIIA) to reduce the

“excessive frequency and severity of health care liability claims in a manner that would not unduly

restrict a claimant’s rights any more than necessary to deal with the crisis.” Rogers v. Bagley, 623

S.W.3d 343, 348–49 (Tex. 2021) (cleaned up). The Legislature replaced the MLIIA with the

TMLA in 2003. Id. at 349. “The TMLA effectuates the Legislature’s goal of deterring frivolous

lawsuits by requiring a claimant early in litigation to produce the opinion of a suitable expert that

his claim has merit.” Id. (cleaned up). Health care liability claims under the TMLA are subject to

various statutory rules, including the requirement that a plaintiff serve the defendant with an expert

report at the beginning of her suit. Tex. Civ. Prac. & Rem. Code Ann. § 74.351.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Putthoff v. Ancrum
934 S.W.2d 164 (Court of Appeals of Texas, 1996)
Lezlea Ross v. St. Luke's Episcopal Hospital
462 S.W.3d 496 (Texas Supreme Court, 2015)
Loaisiga v. Cerda
379 S.W.3d 248 (Texas Supreme Court, 2012)
CHCA Bayshore, L.P. v. Ramos
388 S.W.3d 741 (Court of Appeals of Texas, 2012)
Christus Health Gulf Coast v. Carswell
505 S.W.3d 528 (Texas Supreme Court, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
Pathlink of Texas, LLC v. Ashlee M. Balderrama and Alejandro J. Martinez, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pathlink-of-texas-llc-v-ashlee-m-balderrama-and-alejandro-j-martinez-texapp-2024.