The Estate of Joshua Adam Fuson, by Administratrixes, Amy Hickman and Daffeny Sneed Fuson v. Mercy Regional Emergency Medical System, LLC

CourtCourt of Appeals of Kentucky
DecidedJuly 10, 2024
Docket2023 CA 001242
StatusUnknown

This text of The Estate of Joshua Adam Fuson, by Administratrixes, Amy Hickman and Daffeny Sneed Fuson v. Mercy Regional Emergency Medical System, LLC (The Estate of Joshua Adam Fuson, by Administratrixes, Amy Hickman and Daffeny Sneed Fuson v. Mercy Regional Emergency Medical System, LLC) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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The Estate of Joshua Adam Fuson, by Administratrixes, Amy Hickman and Daffeny Sneed Fuson v. Mercy Regional Emergency Medical System, LLC, (Ky. Ct. App. 2024).

Opinion

RENDERED: JULY 12, 2024; 10:00 A.M. TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2023-CA-1242-MR

THE ESTATE OF JOSHUA ADAM FUSON, BY ADMINISTRATRIXES, AMY HICKMAN AND DAFFENY SNEED FUSON; AUBREY GRACE FUSON, A MINOR BY AND THROUGH HER MOTHER AND NEXT OF FRIEND AMY HICKMAN; AND VICTORIA PAIGE FUSON APPELLANTS

APPEAL FROM MCCRACKEN CIRCUIT COURT v. HONORABLE JOSEPH ROARK, JUDGE ACTION NO. 19-CI-00261

MERCY REGIONAL EMERGENCY MEDICAL SYSTEM, LLC AND SCOTT HENDRICKSON APPELLEES

OPINION AFFIRMING IN PART, REVERSING IN PART, AND REMANDING

** ** ** ** **

BEFORE: THOMPSON, CHIEF JUDGE; COMBS AND LAMBERT, JUDGES.

THOMPSON, CHIEF JUDGE: The Estate of Joshua Adam Fuson, et al., appeal

from an order granting summary judgment in favor of Mercy Regional Emergency Medical System, LLC and Scott Hendrickson. The summary judgment order

dismissed the Estate’s wrongful death claims against Appellees based on a lapse in

the statute of limitations. The order also dismissed the loss of parental consortium

claims of Aubrey Grace Fuson and Victoria Paige Fuson, Joshua Fuson’s minor

daughters, against Appellees. We believe the trial court did not err in dismissing

the Estate’s claims against Appellees; therefore, we affirm that portion of the

summary judgment. We also believe, however, that the trial court did err in

dismissing the daughters’ claims; therefore, we reverse that portion of the

summary judgment and remand for further proceedings.

FACTS AND PROCEDURAL HISTORY

On March 25, 2018, Joshua Fuson ingested methamphetamine and his

family called 911. Officers from the Paducah Police Department responded to the

apartment. Also, an ambulance affiliated with Appellee Mercy Regional attended.

Scott Hendrickson was an emergency medical technician who arrived in the

ambulance. Mr. Fuson was ultimately not cooperative with the police or EMTs

and was taken to McCracken County Jail. While in custody at the jail, Mr. Fuson

suffered a cardiac arrest. He was transported by another ambulance from Mercy

Regional to Baptist Health hospital in Paducah. Unfortunately, Mr. Fuson did not

recover and was pronounced dead on March 27, 2018.

-2- On April 26, 2019, Amy Hickman and Daffeny Fuson were appointed

as co-administrators of Mr. Fuson’s estate. On March 25, 2019, Appellants

brought the underlying complaint against the City of Paducah, Kentucky, three

Paducah Police Department officers, and multiple employees of the McCracken

County Jail. Appellants raised claims of wrongful death and loss of parental

consortium.1 Appellees were not named in the complaint at this time.

On July 27, 2022, Appellants moved to amend their complaint and

add Appellees. The Estate claimed damages for wrongful death, negligence, and

intentional infliction of emotional distress. The daughters, through their mother,

Amy Hickman, raised a claim for damages for loss of parental consortium.2 These

claims were brought over four years after Mr. Fuson’s death.

Appellees eventually moved for summary judgment alleging that the

statute of limitations had run on all the claims raised by Appellants. A hearing was

held September 1, 2023. On September 19, 2023, the trial court granted the

motion for summary judgment in favor of Appellees. The court held that the

causes of action raised by the Estate were required to be brought within one year

pursuant to Kentucky Revised Statutes (KRS) 413.140(1)(a), which states: “The

following actions shall be commenced within one (1) year after the cause of action

1 Other claims were raised, but they are not pertinent to this appeal. 2 In September of 2022, Victoria reached the age of majority.

-3- accrued: (a) An action for an injury to the person of the plaintiff, or of her

husband, his wife, child, ward, apprentice, or servant[.]” The court believed that,

by waiting for four years before naming Appellees, the Estate had missed the

statute of limitations deadline.

As for the claims of the minor children, the trial court also held that

those were barred. The court held that, because loss of parental consortium claims

are derivative of wrongful death claims, and the wrongful death claim in this case

is barred by the statute of limitations, the loss of consortium claim must also be

barred.

Appellants argued before the court that KRS 413.170(1) should apply

to protect the loss of consortium claims. KRS 413.170(1) states:

If a person entitled to bring any action mentioned in KRS 413.090 to 413.160, except for a penalty or forfeiture, was, at the time the cause of action accrued, an infant or of unsound mind, the action may be brought within the same number of years after the removal of the disability or death of the person, whichever happens first, allowed to a person without the disability to bring the action after the right accrued.

Appellants argued that because the children were minors at the time of their

father’s death, they can bring their claims at any time during their infancy or within

one year after they reach the age of majority.

The court ruled that KRS 413.170(1) does not resurrect the loss of

consortium claim even though the children had not yet reached the age of majority.

-4- The court, citing Tallman v. City of Elizabethtown, No. 2006-CA-002542-MR,

2007 WL 3227599 (Ky. App. Nov. 2, 2007), held that the loss of consortium

claims were not tolled by KRS 413.170(1) because the children’s mother raised

other loss of consortium claims on the children’s behalf against other defendants;

therefore, these loss of consortium claims should have been raised at the same

time. The court stated, “initiating a cause of action limits a minor’s ability to claim

that the statute of limitations is then somehow tolled as to other defendants that are

involved in the incident[.]”

This appeal then followed.

STANDARD OF REVIEW

The standard of review on appeal of a summary judgment is whether the trial court correctly found that there were no genuine issues as to any material fact and that the moving party was entitled to judgment as a matter of law. . . . “The record must be viewed in a light most favorable to the party opposing the motion for summary judgment and all doubts are to be resolved in his favor.” Summary “judgment is only proper where the movant shows that the adverse party could not prevail under any circumstances.” Consequently, summary judgment must be granted “[o]nly when it appears impossible for the nonmoving party to produce evidence at trial warranting a judgment in his favor[.]”

Scifres v. Kraft, 916 S.W.2d 779, 781 (Ky. App. 1996) (citations omitted).

“Because summary judgment involves only legal questions and the existence of

any disputed material issues of fact, an appellate court need not defer to the trial

-5- court’s decision and will review the issue de novo.” Lewis v. B & R Corporation,

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