Stackhouse v. Alton Memorial Hospital

CourtDistrict Court, S.D. Illinois
DecidedFebruary 18, 2025
Docket3:22-cv-00246
StatusUnknown

This text of Stackhouse v. Alton Memorial Hospital (Stackhouse v. Alton Memorial Hospital) is published on Counsel Stack Legal Research, covering District Court, S.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Stackhouse v. Alton Memorial Hospital, (S.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

SHANTELA STACKHOUSE, Individually and as Independent Administrator of the Estate of C.M.,

Plaintiff,

v. Case No. 3:22-CV-00246-NJR

UNITED STATES OF AMERICA

Defendant.

MEMORANDUM AND ORDER

ROSENSTENGEL, Chief Judge: This case arises out of a tragic miscarriage that ended a pregnancy. Plaintiff Shantela Stackhouse, individually and as independent administrator of the estate of C.M., brought this action for damages against several institutional and individual healthcare providers who treated her in connection with her pregnancy. Plaintiff named Southern Illinois Healthcare Foundation, Inc., Dr. Geoffrey Lowell Turner, and Dr. Jamie L. Hardman (collectively the “Federal Defendants”) among others, as Defendants in this action. On March 28, 2022, the Court dismissed the Federal Defendants with prejudice and substituted the United States of America in their stead. (Doc. 21). The United States is now the only remaining Defendant in the case.1 Plaintiff’s Third Amended Complaint, the operative complaint here, asserts three claims for relief: medical malpractice on behalf of Shantela Stackhouse (Count I); wrongful death on behalf

1 The two other Defendants, Alton Memorial Hospital and Diane Lahey, RN, settled Plaintiff’s claims against them and were voluntarily dismissed with prejudice. (Docs. 81, 83, 85, and 95). of the estate of C.M. (Count II); and a survival action under the Illinois Survival Act, 755 ILCS 5/27-6, on behalf of the estate of C.M. (Count III). (Doc. 96). The United States

moves for judgment on the pleadings as to Count III, arguing that an unborn fetus cannot accrue a cause of action under the Survival Act. (Doc. 100). BACKGROUND The Court accepts the facts alleged in Plaintiff’s Third Amended Complaint as true. Pisciotta v. Old Nat. Bancorp., 499 F.3d 629, 633 (7th Cir. 2007). On July 23, 2019, at around 9:35 a.m., Plaintiff presented at Alton Memorial

Hospital (“Alton”) complaining of cramps and contractions. Id. ¶ 18. At the time, she was 39 weeks and three days pregnant with C.M., an “unborn, full term and viable baby boy.” Id. A physical exam, vital sign reading, and laboratory testing revealed Plaintiff’s elevated blood pressure and protein in her urine. Id. ¶ 19. The fetal heart rate monitor did not provide reliable information concerning C.M.’s state. Id. At 11:50 a.m., Plaintiff was

discharged from Alton. Id. ¶ 22. Before her discharge, there were “no contraindications for delivery” of C.M. Id. ¶ 23. Later that day at 3:31 p.m., Plaintiff presented at Gateway Regional Medical Center (“Gateway”) via EMS. Id. ¶ 24. Her symptoms had gotten noticeably worse as she was experiencing low blood pressure, vomiting, and abdominal pain. Id. The medical staff at

Gateway was unable to get fetal heart tones from C.M., and Plaintiff was found to have suffered a complete placental abruption. Id. As a result, Plaintiff was taken for an emergency cesarian section. Id. C.M. was delivered at 3:47 p.m. Id. ¶ 25. The staff began performing CPR within minutes, but C.M. was pronounced dead at 4:16 p.m. Id. ¶¶ 26, 27. Plaintiff, meanwhile, was treated for hemorrhaging related to the placental abruption. Id. ¶ 28. LEGAL STANDARD

Federal Rule of Civil Procedure 12(c) provides that “[a]fter the pleadings are closed—but early enough not to delay trial—a party may move for judgment on the pleadings.” Pleadings “include the complaint, the answer, and any written instruments attached as exhibits.” N. Ind. Gun & Outdoor Shows, Inc. v. City of S. Bend, 163 F.3d 449, 452 (7th Cir. 1998).

“The only difference between a motion for judgment on the pleadings and a motion to dismiss is timing; the standard is the same.” Federated Mut. Ins. Co. v. Coyle Mechanical Supply, Inc., 983 F.3d 307, 313 (7th Cir. 2020). A motion for judgment on the pleadings may not be granted “unless it appears beyond doubt that the nonmovant cannot prove facts sufficient to support its position.” Scottsdale Ins. Co. v. Columbia Ins.

Grp., Inc., 972 F.3d 915, 919 (7th Cir. 2020). Thus, even with all facts and inferences viewed in the light most favorable to the nonmoving party, Alexander v. City of Chicago, 994 F.2d 333, 336 (7th Cir. 1993), the moving party must demonstrate that “there are no material issues of fact to be resolved.” N. Ind. Gun & Outdoor Shows, 163 F.3d at 452. DISCUSSION

Count III advances a cause of action sounding in negligence under the Illinois Survival Act. “The Survival Act does not create a statutory cause of action. It merely allows a representative of the decedent to maintain those statutory or common law actions which had already accrued to the decedent before he died.” Advincula v. United Blood Srvs., 678 N.E.2d 1009, 1029 (Ill. 1996). The question here is whether C.M.’s representative may bring a survival action on C.M.’s behalf even though he was stillborn.

The United States relies on the Illinois Supreme Court’s decision in Brucker v. Mercola, 886 N.E.2d 306 (Ill. 2007), to support its contention that a person cannot accrue a cause of action until they are born. In Brucker, Dr. Mercola, the defendant, prescribed Anna Brucker, a pregnant woman, L-glutamine for her allergies and sold it to her directly. Id. at 308-09. Dr. Mercola’s employee mistakenly filled the prescription with selenium, which caused Ms. Brucker to become very ill when she took it. Id. at 309. The plaintiffs

filed suit and included a claim on behalf of Anna’s son Robert, who was born a few months later and was allegedly “poisoned in utero” when Anna ingested the selenium. Id. A critical question in the case was whether the applicable statute of repose was tolled until Robert’s birth. Id. at 326. “[A] cause of action accrues when facts exist that authorize the bringing of a cause of action.” Id. at 329. And with respect to injuries sustained in

utero, the court observed that it and other courts “have generally held that a cause of action for prenatal injuries cannot be maintained until birth.” Id. at 330. “Thus, when a fetus is injured, the occurrence of the injury and the accrual of the cause of action take place at different times. Because no suit may be maintained until birth, that is the time at which facts exist that authorize the bringing of a cause of action and that the claim has

come into being as an enforceable claim or right.” Id. The court concluded that “because liability does not attach until birth and because there is no right to bring a cause of action until birth, the limitations period cannot begin to run until birth.” Id. at 333. This also meant that the repose period “cannot begin to run until the child is born.” Id. at 334. Plaintiff, for her part, argues that the Illinois Supreme Court would likely embrace a survival action on behalf of a stillborn child based on several cases predating Brucker.

She cites Amann v. Faidy,

Related

Pisciotta v. Old National Bancorp
499 F.3d 629 (Seventh Circuit, 2007)
Amann v. Faidy
114 N.E.2d 412 (Illinois Supreme Court, 1953)
Advincula v. United Blood Services
678 N.E.2d 1009 (Illinois Supreme Court, 1996)
Murphy v. Martin Oil Co.
308 N.E.2d 583 (Illinois Supreme Court, 1974)
Brucker v. Mercola
886 N.E.2d 306 (Illinois Supreme Court, 2007)
Chrisafogeorgis v. Brandenberg
304 N.E.2d 88 (Illinois Supreme Court, 1973)
Wyness v. Armstrong World Industries, Inc.
546 N.E.2d 568 (Illinois Supreme Court, 1989)
Woods v. Lancet
102 N.E.2d 691 (New York Court of Appeals, 1951)

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