St. Francis Health, LLC v. Carol Anita Weng

CourtCourt of Appeals of Georgia
DecidedMarch 13, 2020
DocketA19A2082
StatusPublished

This text of St. Francis Health, LLC v. Carol Anita Weng (St. Francis Health, LLC v. Carol Anita Weng) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
St. Francis Health, LLC v. Carol Anita Weng, (Ga. Ct. App. 2020).

Opinion

SECOND DIVISION MILLER, P. J., RICKMAN and REESE, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. http://www.gaappeals.us/rules

March 10, 2020

In the Court of Appeals of Georgia A19A2082. ST. FRANCIS HEALTH, LLC v. WENG.

RICKMAN, Judge.

St. Francis Health, LLC (“SF Health”) appeals from an order of the Muscogee

County State Court denying its motion to dismiss the claims asserted against it by

Carol Anita Weng and granting Weng’s motion to add SF Health as a party-defendant

in the underlying case. SF Health contends that the trial court’s order must be

reversed because Weng’s claims against it are barred by the applicable statute of

limitation, and the trial court erred in concluding otherwise. For reasons explained

more fully below, we agree and therefore reverse the trial court’s order.

We review a trial court’s decision on a motion to add a party to an existing

action for an abuse of discretion. Western Sky Financial, LLC v. State ex rel. Olens,

300 Ga. 340, 357 (3) (a) (793 SE2d 357) (2016). “Such an abuse occurs where the trial court’s ruling is unsupported by any evidence of record or where that ruling

misstates or misapplies the relevant law.” Mathis v. BellSouth Telecommunications,

301 Ga. App. 881, 881 (690 SE2d 210) (2010).

Here, the relevant facts are undisputed and show that Weng, acting individually

and in her capacity as next of kin and executrix of the estate of Lethia Jean

Hemingway, filed the current action on August 29, 2018 against a number of

defendants, including SFH Wind Down, Inc., d/b/a St. Francis Hospital, Inc., d/b/a

St. Francis Hospital (“SFH Wind Down”).1 The complaint asserted a claim for

medical malpractice and alleged that on September 4 and 5, 2016, the defendants

failed to diagnose and treat a pulmonary embolism suffered by Hemingway that

resulted in her death.2

On September 6, 2018, SFH Wind Down’s registered agent received service

of the complaint. That same day, the attorney for SFH Wind Down emailed Weng’s

1 The other named defendants were Max R. Shiver, M.D., John Doe MDs 1-3, John Doe CRNs 1-3, TeamHealth, LLC, and/or XYZ Corp. 1-3. None of the other named defendants is a party to this appeal. 2 The claims asserted against SFH Wind Down were based on the theories of respondeat superior and agency.

2 attorney and informed him that “SFH Wind Down, Inc., . . . f/k/a St. Francis Hospital,

Inc. . . . is currently a Chapter 7 debtor in a bankruptcy . . . .” The email further stated:

I am writing as a courtesy to inform you that you have sued the wrong entity. SFH [Wind Down] sold the assets of St. Francis Hospital in a transaction that was effective January 1, 2016. I believe with due diligence you will find that, at the time of the claim asserted in the Lawsuit (and continuing until the present date), the hospital was owned and operated by St. Francis Health, LLC, a Delaware entity.

Approximately six weeks after receiving that email (and approximately six

weeks after the statute of limitations had expired), Weng filed an amended complaint

in which she named SF Health as a defendant in lieu of SFH Wind Down. Although

the amended complaint purported to drop two previously-named defendants and add

three new party-defendants, including SF Health,3 Weng neither sought nor obtained

leave of court before filing that complaint.

On October 26, SF Health filed a notice of special appearance, together with

an answer, affirmative defenses, and a motion to dismiss. In support of its motion to

3 The complaint also dropped TeamHealth, LLC as a defendant and instead named Inphynet Primary Care Physicians, Southeast, P. C. and Acute-Care Express as defendants.

3 dismiss, SF Health asserted that it could not be added as a party-defendant by way of

an amended complaint. It further argued that because Weng had failed to file her

claims against SF Health or otherwise provide that entity with notice of her lawsuit

within the applicable statute of limitation, Weng’s claims were time-barred.

Approximately one month later, on November 23, Weng filed both a response to the

motion to dismiss and a motion seeking leave of court to dismiss SFH Wind Down

and add SF Health as a party-defendant.

Following a hearing, the trial court entered an order denying the motion to

dismiss and granting Weng leave to add SF Health as a party-defendant. The court

thereafter certified its order for immediate review, and SF Health filed an application

for an interlocutory appeal, which this Court granted. This appeal followed.

SF Health asserts that the trial court erred in denying its motion to dismiss

because Weng failed to bring her claims against it within the applicable statute of

limitation. We agree.

The undisputed evidence shows that the statute of limitation on Weng’s

medical malpractice claims expired on September 5, 2018. See OCGA § 9-3-71 (a)

(“[A]n action for medical malpractice shall be brought within two years after the date

on which an injury or death arising from a negligent or wrongful act or omission

4 occurred.”) Although Weng filed her original complaint within the limitation period,

there is no evidence that SF Health received notice of the action until on or about

October 15, 2018, when Weng filed her unauthorized4 amended complaint naming SF

Health as a new defendant. Despite the fact that Weng presented no evidence showing

that SF Health had notice of the lawsuit until approximately six weeks after the

statute of limitation had expired, the trial court denied the company’s motion to

dismiss and allowed Weng to amend her complaint to add SF Health as a party.

Specifically, the trial court found that such an amendment naming a new party outside

of the limitation period was allowed under OCGA § 9-11-15 and OCGA § 9-11-21.

The statutory subsection on which the trial court relied permits a plaintiff to

add a new party-defendant to her lawsuit after the statute of limitation has expired

where the plaintiff can demonstrate that: (1) the claim asserted in the amended

complaint arises out of the same underlying facts “set forth in the original pleading”;

(2) during the applicable limitation period, the new defendant had notice of the

original lawsuit such that “he will not be prejudiced in maintaining his defense on the

4 See Wright v. Safari Club Int’l, 322 Ga. App. 486, 494 (5) (745 SE2d 730) (2013) (because a court order is required to add or drop parties to a lawsuit, “an amendment to a complaint adding a new party without first obtaining leave of the court is without effect”) (citation and punctuation omitted).

5 merits”; and (3) the new defendant “knew or should have known that, but for a

mistake concerning the identity of the proper party, the action would have been

brought against him.” OCGA § 9-11-15 (c). See also Cartwright v. Fuji Photo Film

U.S.A., 312 Ga. App. 890, 894 (2) (720 SE2d 200) (2011).

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St. Francis Health, LLC v. Carol Anita Weng, Counsel Stack Legal Research, https://law.counselstack.com/opinion/st-francis-health-llc-v-carol-anita-weng-gactapp-2020.