Texas Laurel Ridge Hospital, L.P. D/B/A Laurel Ridge Treatment Center v. Jane Doe, Individually and as Next Friend of Minor Doe, a Minor

Court of Appeals of Texas·Decided June 25, 2025·No. 04-24-00645-CV·Published

Opinion

Fourth Court of Appeals

San Antonio, Texas

MEMORANDUM OPINION

No. 04-24-00645-CV

TEXAS LAUREL RIDGE HOSPITAL, L.P. d/b/a Laurel Ridge Treatment Center, Appellant

v.

Jane DOE, Individually and as Next Friend of Minor Doe, a Minor, Appellee

From the 408th Judicial District Court, Bexar County, Texas Trial Court No. 2022-CI-17725 Honorable Lisa Jarrett, Judge Presiding

Opinion by: Lori Massey Brissette, Justice

Sitting: Irene Rios, Justice Lori Massey Brissette, Justice H. Todd McCray, Justice

Delivered and Filed: June 25, 2025 REVERSED AND REMANDED The issue in this appeal involves the qualification of experts and the sufficiency of expert reports as required by Chapter 74 of the Texas Civil Practice & Remedies Code, also known as the Texas Medical Liability Act (TMLA). The TMLA requires health care liability claimants to serve an expert report upon each defendant not later than 120 days after each defendant’s answer is filed. TEX. CIV. PRAC. & REM. CODE § 74.351(a). The purpose of this threshold requirement “is to weed out frivolous malpractice claims in the early stages of litigation, not to dispose of potentially

meritorious claims.” Abshire v. Christus Health Se. Tex., 563 S.W.3d 219, 223 (Tex. 2018). Appellant Texas Laurel Ridge Hospital, L.P. argues the trial court abused its discretion in failing to find the expert reports filed by Jane Doe deficient and in failing to grant its motion to dismiss. We reverse the trial court’s September 23, 2024 order overruling Laurel Ridge’s objections to Doe’s Chapter 74 expert reports and remand the matter to the trial court to consider whether the claimant should have an opportunity to cure the expert report deficiencies.

FACTS

On February 20, 2021, Minor Doe was admitted to Laurel Ridge Treatment Center, a local behavioral health/psychiatric facility which offers both inpatient admissions and outpatient programming for adults and adolescents. Minor Doe was evidently not responding to outpatient treatment and was demonstrating irritability and suicidal tendencies. As a result of her initial evaluation of Minor Doe upon admission, Dr. Grace Salinas-Garcia ordered Minor Doe be given 24-hour skilled nursing observation, supervision and intervention. Minor Doe was placed among other patients, given a room with one roommate, and checked on four times an hour. However, amidst those checks, Minor Doe alleges he was sexually assaulted by his roommate, a fellow patient. Specifically, a nurse’s note states that at 6:00 am, Minor Doe asked to be removed from his room because his roommate was masturbating. At 4:15 pm the same day, Minor Doe told staff that he’d been sexually abused at 2:00 am that same morning. He was then transported to the Children’s Hospital and was discharged from Laurel Ridge the next day.

Jane Doe, individually and as next friend of Minor Doe, filed this suit under Chapter 74 of the Texas Civil Practice & Remedies Code on April 25, 2023. Doe served expert disclosures pursuant to Texas Rule of Civil Procedure 195.5(a) on July 6, 2023 but did not include expert reports. She did, however, file an expert report from Arnold Mackles, M.D. on September 27, 2023, within 120 days of Laurel Ridge’s filing of its answer. See TEX. CIV. PRAC. & REM. CODE

§ 74.351(a) (requiring expert report to be filed within 120 days of defendant’s answer). Prior to filing the lawsuit, she also forwarded to Laurel Ridge two letters by a counselor, Daniel Arredondo, LPC/LSOTP, who was treating Minor Doe.

Laurel Ridge filed objections to the qualifications of Arredondo and to the sufficiency of his reports on July 27, 2023. Laurel Ridge also filed objections to the qualifications of Dr. Mackles and to the sufficiency of his reports on October 18, 2023. Both filings were timely. See TEX. CIV. PRAC. & REM. CODE § 74.351(a). On September 23, 2024, the trial court entered an order overruling Laurel Ridge’s objections and denying its motion to dismiss. Laurel Ridge then filed this appeal.

STANDARD OF REVIEW

We review a trial court’s ruling on the sufficiency of a Chapter 74 expert report for abuse of discretion. Van Ness v. ETMC First Physicians, 461 S.W.3d 140, 142 (Tex. 2015) (per curiam). Under an abuse of discretion standard, we defer to any factual determinations made by the trial court supported by evidence, and we review the trial court’s legal determinations de novo. Id. The trial court has no discretion in determining what the law is or applying the law to the facts. Walker v. Packer, 827 S.W.2d 833, 840 (Tex. 1992) (orig. proceeding). A clear failure by the trial court to apply the law correctly will constitute an abuse of discretion. Id.

To advance a health care liability claim, a claimant must serve the defendant with an expert report that includes “a fair summary of the expert’s opinions . . . regarding applicable standards of care, the manner in which the care rendered by the physician or health care provider failed to meet the standards, and the causal relationship between that failure and the injury, harm, or damages claimed.” TEX. CIV. PRAC. & REM. CODE § 74.351(r)(6). If a defendant objects to the sufficiency of the report, the trial court may either overrule the objections or grant one thirty-day extension of time to the claimant to give them an opportunity to cure the deficiency if a report’s deficiencies

are curable. TEX. CIV. PRAC. & REM. CODE § 74.351(c); Columbia Valley Healthcare Sys., L.P. v. Zamarripa, 526 S.W.3d 453, 461 (Tex. 2017) (“The Act allows a trial court to grant one 30-day extension to cure a deficiency in an expert report, and a court must grant an extension if a report’s deficiencies are curable.” (footnote omitted)); Loaisiga v. Cerda, 379 S.W.3d 248, 263 (Tex. 2012) (remanding to trial court to consider whether to grant extension of time to cure expert reports).

“A court shall grant a motion challenging the adequacy of an expert report only if it appears to the court, after hearing, that the report does not represent an objective good faith effort to comply with the definition of an expert report in Subsection (r)(6).” TEX. CIV. PRAC. & REM. CODE § 74.351(l). An expert report is considered adequate if it meets the “fair summary” standard set out above. Walker v. Baptist St. Anthony’s Hosp., 703 S.W.3d 339, 342–43 (Tex. 2024) (alterations in original) (citing TEX. CIV. PRAC. & REM. CODE § 74.351(l), (r)(6)); E.D. by & through B.O. v. Texas Health Care, P.L.L.C., 644 S.W.3d 660, 662 (Tex. 2022) (same). An expert report meets the good-faith effort requirement if “it ‘(1) inform[s] the defendant of the specific conduct called into question and (2) provid[es] a basis for the trial court to conclude the claims have merit.’” Baptist St. Anthony’s Hosp., 703 S.W.3d at 343 (alterations in original) (quoting Abshire v. Christus Health Se. Tex., 563 S.W.3d 219, 223 (Tex. 2018)). The purpose of these requirements ‘is to weed out frivolous malpractice claims in the early stages of litigation, not to dispose of potentially meritorious claims.’” Baptist St. Anthony’s Hosp., 703 S.W.3d at 343 (quoting Abshire, 563 S.W.3d at 223).

ARNOLD MACKLES, M.D.

A. Sufficiency of Expert Qualifications Laurel Ridge first argues Dr. Mackles lacked the qualifications necessary to offer an opinion on the subject matter and further argued his expert report failed to adequately outline the appropriate standard of care or link the breach of such care to the proximate cause of Minor Doe’s

injuries. Dr. Mackles was a licensed neonatologist, a medical professional specializing in the care of newborn babies, particularly those born prematurely, from 1983–2005. While still holding a license to practice medicine in Florida and New York, there is nothing in his curriculum vitae or report showing that he still does so. In fact, according to his report and curriculum vitae, he changed his focus twenty years ago, in 2005, from the practice of neonatology to consulting,

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