Puccetti v. Franciscan Communities, Inc.

2025 IL App (1st) 241681-U
CourtAppellate Court of Illinois
DecidedJune 27, 2025
Docket1-24-1681
StatusUnpublished

This text of 2025 IL App (1st) 241681-U (Puccetti v. Franciscan Communities, Inc.) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Puccetti v. Franciscan Communities, Inc., 2025 IL App (1st) 241681-U (Ill. Ct. App. 2025).

Opinion

2025 IL App (1st) 241681-U

SIXTH DIVISION June 27, 2025

No. 1-24-1681

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1).

IN THE APPELLATE COURT OF ILLINOIS FIRST DISTRICT

GREGORY PUCCETTI, as independent executor ) of the estate of KATHLEEN PUCCETTI, deceased, ) ) Appeal from the Plaintiff-Appellant, ) Circuit Court of ) Cook County v. ) ) No. 2020 L 13594 FRANCISCAN COMMUNITIES, INC., an Indiana ) Not-For-Profit Corporation, and FRANCISCAN ) The Honorable SISTERS OF CHICAGO SERVICE ) Michael F. Otto, CORPORATION, an Illinois Not-For-Profit ) Judge Presiding. Corporation, ) ) Defendants-Appellees. )

PRESIDING JUSTICE TAILOR delivered the judgment of the court. Justices Hyman and C.A. Walker concurred in the judgment.

ORDER

¶1 Held: We affirm the grant of summary judgment to defendants.

¶2 I. BACKGROUND

¶3 St. Joseph Village of Chicago (St. Joseph) is a long-term care facility owned and operated

by defendants Franciscan Communities, Inc. and Franciscan Sisters of Chicago Service

Corporation (together, Franciscan). On December 21, 2018, Kathleen Puccetti was admitted to St. No. 1-24-1681

Joseph after she suffered a heart attack and stroke. Her intake paperwork indicated that she suffered

from “unspecified osteoarthritis” and “reduced strength of upper extremities.” While at St. Joseph,

Kathleen required assistance with daily living activities, including walking, toileting, bathing, and

transferring from her bed to a wheelchair.

¶4 On January 6, 2019, while Kathleen was still at St. Joseph, she called her daughter and told

her that a nurse pulled and twisted her arm. She did not tell her daughter who the person was,

however, just that it was someone “in charge of getting her up and moving her.” The next morning,

Kathleen complained of pain and said she was unable to lift her right arm. She was transported to

the emergency room and an x-ray study of her arm was performed, which revealed “body

demineralization without evidence of actual fracture or dislocation” and a “mildly” or

“[m]inimally displaced radial head fracture” of her right arm.

¶5 After learning about Kathleen’s fracture, Olive Mendoza, Franciscan’s Director of

Nursing, conducted an investigation, which included interviewing various staff members. In her

report, Mendoza noted that Kathleen had “no occurrence of fall or other incident[s] during her

stay” at St. Joseph and “never verbalize[d] to anyone in the community that her hand/arm [wa]s

being pulled by staff.” Mendoza concluded that Kathleen’s “minimal displaced radial head fracture

could have [been] caused by stress to the right hand due to the frequent use for bed mobility,

transfer and ambulation with walker while in therapy” and that “[g]iven [Kathleen’s] clinical

condition and weakened bone with diagnosis of OA [osteoarthritis] and osteopenia (CT scan result

from the hospital) the repeated use of the right hand/arm and all body weight going to that hand

might have caused the resident’s bone to break.”

2 No. 1-24-1681

¶6 Kathleen did not return to St. Joseph after her emergency room visit. She died just over

four months later, on May 12, 2019, from “cardiorespiratory failure and aspiration

pneumonia/congestive heart failure.”

¶7 Kathleen’s son, plaintiff Gregory Puccetti (Puccetti), served as independent executor of her

estate. On December 21, 2020, he filed a complaint against Franciscan, alleging that Franciscan’s

negligence caused Kathleen to suffer an arm fracture as well as a sacral pressure injury. However,

he abandoned any claim related to the sacral pressure injury on appeal, so we do not discuss it

here. He also brought a res ipsa loquitur claim against Franciscan, claiming that Kathleen’s

injuries would not have occurred if ordinary care had been exercised by Franciscan. He later

amended his complaint to add a wrongful death claim.

¶8 On June 1, 2023, Franciscan filed a motion for summary judgment, arguing that Puccetti

“failed to offer any evidence indicating [Franciscan’s] acts, or failure to act, were the proximate

cause of [Kathleen’s] injuries or death.” Franciscan argued that although Puccetti alleged it was

negligent in allowing Kathleen to sustain an arm fracture, “[t]his fracture was unwitnessed, and it

would have occurred when she had yet-to-be diagnosed low bone density.” Although Kathleen

made references to a “nurse” hurting her arm, she never named this person or provided any other

identifying details. Therefore, Franciscan argued that summary judgment on the negligence counts

was appropriate, as “no facts in evidence show this alleged person was under the control of

[Franciscan] to tie up the causal connection.” Franciscan also argued that because Kathleen died

more than four months after her discharge from Franciscan and her causes of death were listed as

“cardiorespiratory failure and aspiration pneumonia/congestive heart failure,” it could not be held

liable as Puccetti “failed to present any specific facts” to support a finding that the staff at

Franciscan “caused or contributed to” Kathleen’s death. Finally, Franciscan argued that Puccetti

3 No. 1-24-1681

could not establish res ipsa loquitur, because he “fail[ed] to establish the accident is of the type

that does not ordinarily happen” when ordinary care is exercised. Franciscan noted that Kathleen’s

“right arm x-ray revealed bony demineralization” and argued that “fractures in the presence of

osteopenia (low bone density) do regularly occur, despite ordinary care [being] exercised.”

¶9 In its response, Puccetti argued that genuine issues of material fact existed regarding the

cause of Kathleen’s arm fracture. He pointed to Kathleen’s medical records, which indicated that

Kathleen was transferred by only one staff member on numerous occasions, and argued, based on

his Rule 213 general disclosures, that anticipated testimony from his nursing expert, Charlotte

Sheppard, would create a genuine issue of material fact as to whether Franciscan’s nursing staff’s

failure to perform proper transfers caused Kathleen’s arm fracture. He also argued, based on the

anticipated testimony of Dr. Hollingsworth, an orthopedic surgeon, that “even if Kathleen had

osteopenia and/or osteoarthritis, the condition(s) would not have caused Kathleen’s injury unless

she experienced a fall or some other traumatic event or force.”

¶ 10 In its reply, Franciscan argued that Puccetti failed to offer any evidence of negligence and

instead relied solely on speculation to support his theory that Franciscan caused Kathleen’s right

arm fracture. Franciscan also argued that the proposed testimony of Puccetti’s controlled experts,

nurse Sheppard and Dr. Hollingsworth, could not be considered as “neither [expert] ha[d] sworn

to their disclosed opinions under penalties of perjury,” and that “[a]ny attempt to create triable

questions of fact arising out of the unverified, disclosed opinions of controlled expert witnesses

who have not yet testified at deposition or submitted an affidavit is improper at the summary

judgment stage.”

¶ 11 Dr. Hollingsworth was deposed on April 11, 2024. At the hearing on Franciscan’s motion

for summary judgment, which took place on April 19, 2024, Franciscan argued that Puccetti failed

4 No. 1-24-1681

to establish a genuine issue of material fact on breach of duty and causation because there was no

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2025 IL App (1st) 241681-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/puccetti-v-franciscan-communities-inc-illappct-2025.