Shawanda Evans Jackson, Duly Appointed Testamentary of the Estate of Willie E. Jackson, Jr. v. Willis-Knighton Health System d/b/a Willis-Knighton Medical Center

CourtLouisiana Court of Appeal
DecidedApril 13, 2022
Docket54,405-CA
StatusPublished

This text of Shawanda Evans Jackson, Duly Appointed Testamentary of the Estate of Willie E. Jackson, Jr. v. Willis-Knighton Health System d/b/a Willis-Knighton Medical Center (Shawanda Evans Jackson, Duly Appointed Testamentary of the Estate of Willie E. Jackson, Jr. v. Willis-Knighton Health System d/b/a Willis-Knighton Medical Center) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Shawanda Evans Jackson, Duly Appointed Testamentary of the Estate of Willie E. Jackson, Jr. v. Willis-Knighton Health System d/b/a Willis-Knighton Medical Center, (La. Ct. App. 2022).

Opinion

Judgment rendered April 13, 2022. Application for rehearing may be filed within the delay allowed by Art. 2166, La. C.C.P.

No. 54,405-CA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

SHAWANDA EVANS JACKSON, Plaintiff-Appellant DULY APPOINTED TESTAMENTARY EXECUTRIX OF THE ESTATE OF WILLIE E. JACKSON, JR.

versus

WILLIS-KNIGHTON HEALTH Defendant-Appellee SYSTEM D/B/A WILLIS- KNIGHTON MEDICAL CENTER

Appealed from the First Judicial District Court for the Parish of Caddo, Louisiana Trial Court No. 622,051

Honorable Ramon Lafitte, Judge

SHAWANDA EVANS JACKSON In Proper Person

WATSON, BLANCHE, WILSON & POSNER Counsel for Appellee By: Shelby G. LaPlante

Before MOORE, ROBINSON, and HUNTER, JJ. MOORE, C.J.

A hospital patient, Willie E. Jackson, brought an action against Willis-

Knighton Medical Center (“Willis-Knighton” or “hospital”) seeking

damages for injuries he sustained when he fell off a gurney while being

transported to a hospital room by hospital employees. The hospital filed an

exception of prematurity on grounds that the plaintiff had not first presented

his claim to a medical review panel (“MRP”). Before the matter was

decided, the plaintiff passed away; his widow, Shawanda Jackson, was

substituted as plaintiff. Following amendments to the original petition and a

hearing on Willis-Knighton’s renewed exception of prematurity, the district

court held that the plaintiff’s claim sounded in medical malpractice, granted

the exception of prematurity, and dismissed the plaintiff’s petition without

prejudice.

This appeal followed. For the following reasons, we affirm.

FACTS

Willie E. Jackson, age 68, filed a “petition for medical malpractice”

on January 30, 2020, alleging that Willis-Knighton committed malpractice

due to substandard medical care while he was a patient being transported on

a gurney to a hospital room. Specifically, he alleged that he was dumped or

allowed to fall off a gurney or stretcher and sustained serious injuries as a

result. Willis-Knighton responded with a dilatory exception of prematurity,

arguing that the medical malpractice claim must be first reviewed by an

MRP convened pursuant to the Louisiana Medical Malpractice Act

(“LMMA” or “the Act”). Although Jackson had filed a complaint with the

Louisiana Division of Administration Patient’s Compensation Fund for

appointment of an MRP just nine days before he filed the petition, the complaint was not reviewed by an MRP before he filed his petition for

medical malpractice in district court.

A hearing on Willis-Knighton’s exception was initially set for July 27,

2020, but Jackson passed away one week before the scheduled hearing. The

matter was continued. His wife, Shawanda Evans Jackson, appearing pro se

as executrix of his estate, was substituted as party plaintiff. Ms. Jackson

also filed an amended petition, dropping the original allegations of medical

malpractice; instead, she characterized the claim as a “petition for damages”

for general negligence, thereby attempting to avoid an MRP.

Factually, the amended petition alleged that on January 31, 2019,

Jackson was admitted to the emergency room of Willis-Knighton North

about 2:30 p.m., after becoming disoriented at a dialysis center. A series of

tests, including a CT scan and MRI, indicated that he suffered a series of

mini-strokes, sometimes called transient ischemic attacks (“TIAs”). As his

condition improved and he became coherent, he was in the process of being

transported to a hospital room when the accident occurred. The petition

alleged that while the two hospital employees were rolling the gurney into

the elevator, Jackson was dumped or fell from the gurney or stretcher. The

petition alleged that Jackson suffered injuries, including a swollen face,

bruises, an eye injury, and humiliation because the employees laughed at

him. Further, the injury caused his mental status to deteriorate such that he

could not talk or move, and had bruises all over his body.

A hearing on the exception of prematurity was finally held on March

15, 2021. At the hearing, the court explained to Ms. Jackson the MRP

process was required by law and that her petition could not be filed until that

process had run its course, that she would not be prejudiced by whatever 2 decision the MRP rendered, and she could still file a suit if she was not

satisfied by the MRP’s decision. Nevertheless, Ms. Jackson persisted in her

position that her claim lay outside the LMMA, and she persuaded the court

to allow her to amend her petition again. The court gave Ms. Jackson two

weeks to amend her petition and reset a hearing for June 28, 2021.

Ms. Jackson timely filed an “amended petition for general damages

under Louisiana premise liability.” The operative new allegation reads:

Additional Facts that defendants had actual knowledge of the defective elevator incident at its facility . . . on February 1, 2019 at 10:45 a.m., at time they Hit and Dumped Patient, Willie E. Jackson, Jr. Entire (270 lbs.) Body into the Elevator’s floor and wall and allowed the unsafe Stretcher to Hit and/or assault; Causing severe injuries to head, face and entire body at or about that time and place the accident occurred. (Emphasis in original.)

The petition further alleged that Willis-Knighton had actual knowledge of

Jackson’s preexisting condition (TIAs) that hastened his death, and actual

knowledge that the elevators are not covered by the LMMA. It alleged

Jackson was an “inpatient/invitee” covered by Louisiana premise liability

law.

At the June 28, 2021, hearing, Ms. Jackson argued that Willis-

Knighton’s employees transporting Jackson on the gurney “dumped him in

the elevator as a result of the malfunctioning elevator not being level, which

is outside the scope of medical malpractice.” She argued that “it is not

malpractice” because “[t]he elevator is what caused it.”

Willis-Knighton argued that notwithstanding how the plaintiff styled

her petition, the allegations fell within the scope of the LMMA, which

applies to any unintentional tort based on health care or professional

3 services, including handling a patient, loading and unloading a patient, or

transporting a patient.

The district court agreed. It granted Willis-Knighton’s exception of

prematurity and dismissed the petition without prejudice.

This appeal followed.

DISCUSSION

On appeal, the pro se plaintiff asserts three assignments of error that

have no bearing on the judgment appealed from or on any issue of law

before the court, namely, whether the judgment granting the exception of

prematurity dismissing the petition without prejudice was correct.

Accordingly, we defer discussion of the merits of the assignments raised by

the plaintiff until the end of this opinion.

The LMMA governs medical malpractice claims filed in the State of

Louisiana. La. R.S. 40:1231.1 et seq. The Act defines “malpractice” as

any unintentional tort or any breach of contract based on health care or professional services rendered, or which should have been rendered, by a health care provider, to a patient, including failure to render services timely and the handling of a patient including loading and unloading of a patient[.] (Emphasis added.)

La. R.S. 40:1231.1 A(13).

A medical malpractice claim against a private qualified health care

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Shawanda Evans Jackson, Duly Appointed Testamentary of the Estate of Willie E. Jackson, Jr. v. Willis-Knighton Health System d/b/a Willis-Knighton Medical Center, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shawanda-evans-jackson-duly-appointed-testamentary-of-the-estate-of-willie-lactapp-2022.