Sealy Emergency Room, L.L.C. and Kannappan Krishnaswamy, M.D. v. Dr. Atul Dhingra, Dr. Swapan Dubey and Dr. Sanjeev Dubey

CourtCourt of Appeals of Texas
DecidedAugust 29, 2024
Docket01-21-00008-CV
StatusPublished

This text of Sealy Emergency Room, L.L.C. and Kannappan Krishnaswamy, M.D. v. Dr. Atul Dhingra, Dr. Swapan Dubey and Dr. Sanjeev Dubey (Sealy Emergency Room, L.L.C. and Kannappan Krishnaswamy, M.D. v. Dr. Atul Dhingra, Dr. Swapan Dubey and Dr. Sanjeev Dubey) 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.

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Sealy Emergency Room, L.L.C. and Kannappan Krishnaswamy, M.D. v. Dr. Atul Dhingra, Dr. Swapan Dubey and Dr. Sanjeev Dubey, (Tex. Ct. App. 2024).

Opinion

Opinion issued August 29, 2024

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-21-00008-CV ——————————— SEALY EMERGENCY ROOM, L.L.C. AND KANNAPPAN KRISHNASWAMY, M.D., Appellants v. FREE STANDING EMERGENCY ROOM MANAGERS OF AMERICA, L.L.C., DR. ATUL DHINGRA, DR. SWAPAN DUBEY, AND DR. SANJEEV DUBEY, Appellees

On Appeal from the 125th District Court Harris County, Texas Trial Court Case No. 2018-48143-A

MEMORANDUM OPINION

Appellants, Sealy Emergency Room, L.L.C. (“Sealy ER”) and Kannappan

Krishnaswamy, M.D., challenge the trial court’s rendition of summary judgment in

favor of appellees, Free Standing Emergency Room Managers of America, L.L.C. (“FERMA”), Dr. Atul Dhingra, Dr. Swapan Dubey, and Dr. Sanjeev Dubey (the

“third-party doctors”) (collectively, “appellees”), on Sealy ER’s and Dr.

Krishnaswamy’s counterclaims and third-party claims for breach of contract, fraud,

fraudulent inducement, and negligence.

On the original submission of this appeal, consistent with this Court’s

precedent, we dismissed Sealy ER’s and Dr. Krishnaswamy’s appeal for lack of

appellate jurisdiction because of the manner in which the trial court had severed the

issues on appeal from the main case. See Sealy Emergency Room LLC v. Free

Standing Emergency Room Managers of Am., L.L.C., 669 S.W.3d 488, 493–94 (Tex.

App.—Houston [1st Dist.] 2022), rev’d, 685 S.W.3d 816 (Tex. 2024). Sealy ER and

Dr. Krishnaswamy then filed a petition for review with the Texas Supreme Court,

asserting that this Court had jurisdiction over their appeal. Holding that the trial

court’s severance ruling did not determine the severed case’s appealability, the

Texas Supreme Court reversed and remanded the case for this Court to consider

Sealy ER’s and Dr. Krishnaswamy’s appeal on the merits. See Sealy Emergency

Room, L.L.C. v. Free Standing Emergency Room Managers of Am., L.L.C., 685

S.W.3d at 820–24, 826 (Tex. 2024).

In three issues, Sealy ER and Dr. Krishnaswamy contend that the trial court

erred in granting summary judgment.

We affirm.

2 Background

FERMA, a company specializing in the management of free-standing

emergency rooms, brought suit against Sealy ER and Dr. Krishnaswamy after a

dispute arose from a contractual relationship between FERMA, Sealy ER, and Dr.

Krishnaswamy for the management of Sealy ER, an emergency room facility located

in Sealy, Texas. In its first amended petition, FERMA brought claims for breach of

contract and a declaratory judgment against Sealy ER and Dr. Krishnaswamy.

In their first amended answer and counterclaim, Sealy ER and Dr.

Krishnaswamy generally denied the allegations in FERMA’s petition and brought

counterclaims against FERMA for breach of contract, fraud, fraudulent inducement,

and negligence. Sealy ER and Dr. Krishnaswamy alleged that they had entered into

a contract with FERMA, titled “The Emergency Department Amended Management

Agreement” (the “amended management agreement”) in February 2015. As to their

breach-of-contract counterclaim, Sealy ER and Dr. Krishnaswamy alleged that

FERMA had breached its contractual duties to “educate and orient new physicians

to the facility”; update the policies and procedures manual; “provide a billing liaison

representative” and “enhance cash flow”; “train and educate . . . staff”; engage in

business development and marketing initiatives; adhere to the mandated laboratory

compliance program; provide supervisory personnel; “produce copies of its

employee[s’] workman compensation/personal/professional insurances”; “keep

3 confidential proprietary information of Sealy ER”; “comply with HIPAA”; and

make “changes in . . . policies [and] procedures,” including disaster preparation

policies. As to their counterclaims for fraud and fraudulent inducement, Sealy ER

and Dr. Krishnaswamy alleged that FERMA committed fraud and fraudulently

induced them to enter the contract by falsely representing that it was proficient in

managing “billing issues”; able to provide various services, including business

development, consulting, and risk management services, and the recruitment of

“qualified and appropriate” physicians; and capable of complying with state

regulatory and licensing requirements. Such representations were made with the

intent that Sealy ER and Dr. Krishnaswamy would rely on them, FERMA knew the

representations were false, and Sealy ER and Dr. Krishnaswamy relied on the

representations. As a result, Sealy ER and Dr. Krishnaswamy suffered damages.

Finally, as to their negligence counterclaim, Sealy ER and Dr. Krishnaswamy

alleged that FERMA owed them “a duty to accomplish its tasks consistent with

standards in the industry” and by engaging in the aforementioned conduct FERMA

breached its duty, proximately causing damages to Sealy ER and Dr Krishnaswamy.

In its amended third-party petition, Sealy ER brought third-party claims for

fraud, fraudulent inducement, and negligence against the third-party doctors. As to

its third-party claims for fraud and fraudulent inducement, Sealy ER alleged that the

same conduct that served as the basis for its counterclaims against FERMA served

4 as the basis for its third-party fraud and fraudulent-inducement claims. As to its

third-party negligence claim, Sealy ER alleged that the third-party doctors had a

“duty to accomplish [their] tasks with standards in the industry.” According to Sealy

ER, the third-party doctors “had personal knowledge of the need to have the Sealy

ER [l]aboratory in compliance with state laboratory requirements,” yet “Texas

compliance authorities . . . failed Sealy ER” “on two separate occasions.” And

although the third-party doctors were “aware of state and federal[] . . . HIPAA

requirements,” they “failed to obtain proper administrative HIPAA consent to avoid

impermissible use or disclosure of clinical information that compromise[d] the

security [and] privacy of . . . patients’ health information.” That breach “placed in

jeopardy” Sealy ER’s ability to operate. As a result of the third-party doctors’

negligence, Sealy ER suffered damages.

Appellees filed a motion for partial summary judgment against Sealy ER and

Dr. Krishnaswamy, asserting that they were entitled to judgment as a matter of law

on Sealy ER’s and Dr. Krishnaswamy’s counterclaim against FERMA for breach of

contract and Sealy ER’s and Dr. Krishnaswamy’s counterclaims and third-party

claims against appellees for fraud, fraudulent inducement, and negligence.

According to appellees, in 2014, FERMA and Sealy ER entered a contract “in which

FERMA agreed to manage Sealy ER in exchange for a monthly payment of

$40,000.” In February 2015, “due to Sealy ER’s worsening financial condition, the

5 parties negotiated” the amended management agreement, in which “FERMA agreed

to reduce its monthly fee.” The parties performed under that contract until 2018. In

spring 2018, Dr. Krishnaswamy approached FERMA “and asked if FERMA would

mutually agree to terminate” the amended management agreement, but FERMA

declined to do so. Then, Dr. Krishnaswamy “wrongfully terminated” the amended

management agreement, which led FERMA to file suit against Sealy ER and Dr.

Krishnaswamy for breach of contract and a declaratory judgment. Sealy ER and Dr.

Krishnaswamy then filed counterclaims and thirty-party claims against appellees.

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Sealy Emergency Room, L.L.C. and Kannappan Krishnaswamy, M.D. v. Dr. Atul Dhingra, Dr. Swapan Dubey and Dr. Sanjeev Dubey, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sealy-emergency-room-llc-and-kannappan-krishnaswamy-md-v-dr-atul-texapp-2024.