Robledo v. United States

CourtDistrict Court, W.D. Texas
DecidedSeptember 17, 2024
Docket6:23-cv-00796
StatusUnknown

This text of Robledo v. United States (Robledo v. United States) is published on Counsel Stack Legal Research, covering District Court, W.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Robledo v. United States, (W.D. Tex. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS WACO DIVISION

H.R. A MINOR THROUGH HER § MOTHER AND NEXT FRIEND DESTINY § ROBLEDO, DESTINY ROBLEDO § INDIVIDUALLY, AND JIMMY § ROBLEDO, § No. W:23-CV-00796-ADA-JCM Plaintiffs, § § v. § § UNITED STATES OF AMERICA, § Defendant. §

REPORT AND RECOMMENDATION OF THE UNITED STATES MAGISTRATE JUDGE

TO: THE HONORABLE ALAN D ALBRIGHT, UNITED STATES DISTRICT JUDGE

This Report and Recommendation is submitted to the Court pursuant to 28 U.S.C. § 636(b)(1)(C), Fed. R. Civ. P. 72(b), and Rules 1(d) and 4(b) of Appendix C of the Local Rules of the United States District Court for the Western District of Texas, Local Rules for the Assignment of Duties to United States Magistrate Judges. Before the Court are Defendant’s Motion to Dismiss (ECF No. 10), Plaintiff’s Opposition to Defendant’s Motion to Dismiss (ECF No. 12), Plaintiff’s Amended Opposition to Defendant’s Motion to Dismiss (ECF No. 14), and Defendant’s Reply to Plaintiff’s Amended Opposition to Defendant’s Motion to Dismiss (ECF No. 15). For the following reasons, the undersigned RECOMMENDS Defendant’s Motion be GRANTED. I. BACKGROUND Plaintiffs Destiny Robledo and Jimmy Robledo sue the United States of America under the Federal Torts Claim Act “for negligence and/or willful and wanton negligence (gross negligence) and professional malpractice” relating to obstetrical medical care provided by Keilah Ketron, D.O., and Kimberly Micus, M.D. Pl.’s Am. Compl. (ECF No. 6) at 1. Plaintiff Destiny Robledo sues on behalf of H.R., a minor, and herself. Id. Plaintiffs allege that on January 11, 2021, Destiny Robledo arrived at the Baylor Scott & White Medical Center to deliver H.R. Id. at 2. Upon admission, Destiny was treated by Dr.

Ketron, a second-year family medicine resident physician. Id. Dr. Ketron observed that H.R. was suffering from shoulder dystocia, a condition in which the baby’s right shoulder is stuck behind the mother’s public symphysis, during delivery. Id. “Dr. Ketron applied, according to the hospital record, ‘moderate traction’ to (pulled on) H.R.’s head” to resolve the shoulder dystocia. Id. Plaintiffs allege that “the total length of the shoulder dystocia was 110 seconds.” Id. Plaintiffs assert that the short amount of time indicates that the care was not emergency medical care. Id. Plaintiffs allege that Dr. Ketron, through negligence or gross negligence, caused H.R. to suffer severe and permanent injuries to her brachial plexus nerves. Id. at 2–3. Plaintiffs allege that Dr. Micus acted negligently or grossly negligently failed to supervise Dr. Ketron during

Destiny’s labor. Id. at 3. II. LEGAL STANDARDS Federal Rule of Civil Procedure 12(b)(1) allows a party to assert lack of subject matter jurisdiction as a defense to suit. Fed. R. Civ. P. 12(b)(1). Federal district courts are courts of limited jurisdiction and may only exercise such jurisdiction as is expressly conferred by the Constitution and federal statutes. Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 (1994). A federal court properly dismisses a case for lack of subject matter jurisdiction when it lacks the statutory or constitutional power to adjudicate the case. Home Builders Ass'n of Miss., Inc. v. City of Madison, 143 F.3d 1006, 1010 (5th Cir. 1998). “The burden of proof for a Rule 12(b)(1) motion to dismiss is on the party asserting jurisdiction.” Ramming v. United States, 281 F.3d 158, 161 (5th Cir. 2001), cert. denied, 536 U.S. 960 (2002). “Accordingly, the plaintiff constantly bears the burden of proof that jurisdiction does in fact exist.” Id. In ruling on a Rule 12(b)(1) motion, the court may consider any one of the following: (1) the complaint alone; (2) the complaint plus undisputed facts evidenced in the record; or (3) the complaint, undisputed

facts, and the court's resolution of disputed facts. Lane v. Halliburton, 529 F.3d 548, 557 (5th Cir. 2008). III. DISCUSSION The FTCA imposes liability on the Government “in accordance with the law of the place where the act or omission occurred” for “injury or loss of property, or personal injury or death caused by the negligent or wrongful act” of federal employees acting within the course and scope of their employment. 28 U.S.C. § 1346(b)(1). Because the alleged malpractice in this case occurred in Texas, Texas law applies. Ellis v. United States, 673 F.3d 367, 372 (5th Cir. 2012). Under Texas law, medical malpractice claims are governed by the Texas Medical Liability Act

(“TMLA”). Id. at 378. When a medical provider provides emergency medical care in an obstetrical unit, the TMLA requires the claimant to prove that the provider breached the applicable standard of care with willful and wanton negligence. Tex. Civ. Prac. & Rem. Code § 74.153(a). The United States argues that shoulder dystocia constitutes an obstetrical emergency requiring a finding of willful and wanton conduct to impose liability. Def.’s Mot. at 3. Plaintiff argues that whether shoulder dystocia constitutes a medical emergency is a fact-question which cannot be resolved at the motion to dismiss stage. Pl.’s Am. Resp. at 15. The Court notes that the overwhelming majority of cases addressing shoulder dystocia held that it was a medical emergency. See, e.g., Tex. Health Presbyterian Hosp. of Denton v. D.A., 569 S.W.3d 126 (Tex. 2018) (holding that shoulder dystocia is an obstetrical emergency); see also Taber v. Roush, 316 S.W.3d 139, 144 (Tex. App.—Houston [14th Dis.] 2010, no pet.) (“Shoulder dystocia is an obstetric emergency. To avoid brain damage to the baby from lack of oxygen due to cord compression, the shoulder dystocia must be resolved quickly so that the delivery can be

completed.”); Banks v. Columbia Hosp. at Med. City Dallas Subsidiary, L.P., 233 S.W.3d 64, 70–71 (Tex. App.—Dallas 2007, pet. denied) (holding that shoulder dystocia is an obstetrical emergency); and Franka v. Velasquez, 332 S.W.3d 367, 370 (Tex. 2011) (“a relatively infrequent but well-recognized obstetric emergency known as shoulder dystocia.”). In fact, the Court can find only one case suggesting that shoulder dystocia may not be an emergency. See Glenn v. Leal, 596 S.W.3d 769, 772 (Tex. 2020) (“the issue of whether Dr. Glenn provided emergency care to Dawn was critical and contested” where the doctor’s request that the jury be asked whether he provided emergency care was denied.).

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Related

Lane v. Halliburton
529 F.3d 548 (Fifth Circuit, 2008)
Molzof v. United States
502 U.S. 301 (Supreme Court, 1992)
Kokkonen v. Guardian Life Insurance Co. of America
511 U.S. 375 (Supreme Court, 1994)
Bobby Battle v. U.S. Parole Commission
834 F.2d 419 (Fifth Circuit, 1987)
Ellis Ex Rel. A.M.G. v. United States
673 F.3d 367 (Fifth Circuit, 2012)
Franka v. Velasquez
332 S.W.3d 367 (Texas Supreme Court, 2011)
Taber v. Roush
316 S.W.3d 139 (Court of Appeals of Texas, 2010)
Banks v. Columbia Hospital at Medical City Dallas Subsidiary, L.P.
233 S.W.3d 64 (Court of Appeals of Texas, 2007)

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Robledo v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/robledo-v-united-states-txwd-2024.