Thiel v. Adams County Public Hospital District 2

CourtDistrict Court, E.D. Washington
DecidedJune 2, 2022
Docket2:21-cv-00279
StatusUnknown

This text of Thiel v. Adams County Public Hospital District 2 (Thiel v. Adams County Public Hospital District 2) is published on Counsel Stack Legal Research, covering District Court, E.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Thiel v. Adams County Public Hospital District 2, (E.D. Wash. 2022).

Opinion

1 EASTERUN. SD.I SDTIRSITCRTI COTF CWOAUSRHTI NGTON Jun 02, 2022 2 SEAN F. MCAVOY, CLERK 3 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 4 ESTATE OF KAREN THIEL, and No. 2:21-cv-00279-SMJ 5 LAMAR THIEL, and the marital community thereof, ORDER REGARDING MOTION 6 TO DISMISS Plaintiffs, 7 v. 8 ADAMS COUNTY PUBLIC 9 HOSPITAL DISTRICT #2, a Washington Public Hospital District 10 doing business as East Adams Rural Healthcare doing business as East 11 Adams Rural Hospital, and MATTHEW MECHAM, an individual, 12 Defendants. 13

14 Before the Court, without oral argument, is Defendants’ Motion for Partial 15 Dismissal for Failure to State a Claim Pursuant to FRCP 12(b)(6), ECF No. 12. 16 After review of the motion and the file, the Court grants the motion in part and 17 denies it in part. 18 BACKGROUND 19 Prior to her death on September 29, 2021, Karen Thiel was a lewy body 20 dementia patient who spent two stays at East Adams Rural Hospital’s swing bed 1 facility in 2019, one beginning in January and ending in late February, and another 2 beginning in May and continuing until October. See ECF Nos. 5 at 3–6; 18 at 2.

3 According to Plaintiffs’ First Amended Complaint, Ms. Thiel’s communication 4 skills were limited during her stays at the Hospital due to her dementia, and she 5 required “specialized attention and assessment to receive the quality of care the

6 other patients routinely received.” ECF No. 5 at 2. The claims at issue here 7 principally concern the care Ms. Thiel received surrounding two falls she suffered 8 while at the Hospital, though Plaintiffs also allege deficient treatment for Ms. 9 Thiel’s ulcer.

10 A. First Fall – January 29, 2019 11 In the early morning of January 29, 2019, Ms. Thiel exhibited “a physical 12 need,” but Hospital staff “ignored that need and left her alone in her chair.” ECF

13 No. 5 at 3; see also ECF No. 18 at 2 (“[S]taff ignored clear signs that Karen Thiel 14 had a physical need, perhaps to move to the restroom or engage in some other 15 activity.”). As a result, “she attempted to stand up and suffered a fall,” breaking her 16 hip. ECF No. 5 at 3. Hospital nursing staff, including Matthew Mecham, knew of

17 the fall immediately after it occurred. Id. (“According to [Hospital] records, 18 Mecham heard Karen Thiel calling for help and heard her complaining about hip 19 pain.”).

20 // 1 After Ms. Thiel fell, “staff did not properly examine [her] for injuries.” Id. at 2 4. Instead, staff “placed her back in her chair and undertook no other efforts to

3 provide the care she needed.” Id. No staff member entered the fall into Ms. Thiel’s 4 medical chart and staff “failed to inform other staff about the fall.” Id. Because of 5 these failures, the Hospital “moved Karen Thiel and attempted to have her walk on

6 her broken hip on multiple occasions before [] her injuries were detected.” Id. “Staff 7 members charted that they knew of no reason for her to be in pain.” Id. 8 A day or two after the fall, physical therapy staff discovered the injury when 9 they attempted to make Ms. Thiel walk. Id. The next day—approximately 36 hours

10 after he witnessed Ms. Thiel fall—Mr. Mecham updated Ms. Thiel’s chart, 11 “attempt[ing] to create a backdated record of the fall.” Id. at 4–5. As a result of her 12 injury, Ms. Thiel was sent to Spokane, Washington for surgery. Id. at 4. She later

13 returned for a second stay at the Hospital to recuperate. Id. 14 Plaintiffs allege, based upon information and belief, that Hospital staff, 15 including Mr. Mecham, treated Ms. Thiel differently than other Hospital patients 16 because she had dementia and a limited ability to communicate, meaning she was

17 unable to complain about neglect, mistreatment, pain, or other issues with the 18 quality of her care. Id. at 5. 19 //

20 // 1 B. Second Fall – August 29, 2019 2 On the evening of August 29, 2019, Karen was left in the Hospital dining

3 area in the care of “Steve with environmental services,” who was not a licensed 4 medical provider. Id. Plaintiff alleges that other patients at EARH were not left in 5 the care of Steve. Id. at 6. Eventually, Steve also left the dining area, leaving Ms.

6 Thiel without any Hospital staff. Id. While alone, Ms. Thiel suffered a fall, causing 7 her pain, suffering, and emotional distress. Id. 8 C. Pressure Ulcer 9 Less relevant to the issues addressed in this Order, Plaintiffs also allege that

10 when Ms. Thiel was admitted to the Hospital in May of 2019, she had a pressure 11 ulcer. Id. Hospital staff allegedly breached the standard of care by treating the 12 wound improperly for more than three months without reassessing the treatment

13 strategy. Id. As a result, Ms. Thiel suffered delayed healing, increased pain and 14 suffering and other damages. Id. 15 D. Complaint and Allegations 16 Plaintiffs Lamar Thiel and the Estate of Karen Thiel bring four claims against

17 East Adams Rural Hospital and Matthew Mecham. Id. at 6–8. First, Plaintiffs bring 18 a medical negligence claim, alleging that the Hospital and its staff breached their 19 duty of care on multiple occasions by negligently providing care to Ms. Thiel,

20 resulting in “damages, including, but not limited to injuries, emotional distress and 1 pain and suffering.” Id. at 7. Second, Plaintiffs bring a claim against Mr. Mecham 2 under 42 U.S.C. § 1983, alleging that Mr. Mecham, with no rational basis for doing

3 so, “deprived Ms. Thiel of her constitutional rights by failing to document or inform 4 other staff of her January 29, 2019 fall until many hours after it occurred . . . because 5 [Ms.] Thiel is a dementia patient with limited ability to advocate for herself or

6 inform others of her mistreatment.” Id.1 Third, Plaintiffs bring a claim in ordinary 7 negligence, alleging that the Hospital breached its duty of care on at least one 8 occasion, causing Ms. Thiel to suffer damages, including but not limited to, pain 9 and suffering. Id. at 8. Fourth, and finally, Plaintiffs sue for unlawful discrimination

10 under the Washington Law Against Discrimination, alleging that Ms. Thiel received 11 inferior care because she had dementia. Id. Defendant seek dismissal of Plaintiff’s 12 Second, Third, and Fourth claims. ECF No. 12 at 1–2 (citing Fed. R. Civ. P. 12(b)(1)

13 and 12(b)(6)). 14 LEGAL STANDARD 15 A complaint must contain “a short and plain statement of the claim showing 16 that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). Under Federal Rule of

18 1 Plaintiffs’ Second Claim, in the main, refers only to Mr. Mecham, but on one occasion refers to Mr. Mecham and the Hospital. ECF No. 5 at 7. Nevertheless, in 19 Plaintiffs’ response to the motion to dismiss, Plaintiffs aver that the claim is brought against only Mr. Mecham, and so the Court will proceed as though he is the only 20 defendant against whom Plaintiffs lodge a Section 1983 claim. See ECF No. 18 at 9. 1 Civil Procedure 12(b)(6), the Court must dismiss the complaint if it “fail[s] to state 2 a claim upon which relief can be granted.”

3 In deciding a Rule 12(b)(6) motion, the Court construes the complaint in the 4 light most favorable to the plaintiff and draws all reasonable inferences in the 5 plaintiff’s favor. Ass’n for L.A. Deputy Sheriffs v. County of Los Angeles, 648 F.3d

6 986, 991 (9th Cir. 2011). Thus, the Court must accept as true all factual allegations 7 contained in the complaint.

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Thiel v. Adams County Public Hospital District 2, Counsel Stack Legal Research, https://law.counselstack.com/opinion/thiel-v-adams-county-public-hospital-district-2-waed-2022.