TTHR, LP, D/B/A Presbyterian Hospital of Denton v. Amanda Coffman

CourtCourt of Appeals of Texas
DecidedMarch 17, 2011
Docket02-10-00162-CV
StatusPublished

This text of TTHR, LP, D/B/A Presbyterian Hospital of Denton v. Amanda Coffman (TTHR, LP, D/B/A Presbyterian Hospital of Denton v. Amanda Coffman) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
TTHR, LP, D/B/A Presbyterian Hospital of Denton v. Amanda Coffman, (Tex. Ct. App. 2011).

Opinion

02-10-162-CV

COURT OF APPEALS

SECOND DISTRICT OF TEXAS

FORT WORTH

NO. 02-10-00162-CV

TTHR, L.P. D/B/A PRESBYTERIAN HOSPITAL OF DENTON

APPELLANT

V.

AMANDA COFFMAN

APPELLEE

------------

FROM THE 211TH DISTRICT COURT OF DENTON COUNTY

OPINION

TTHR, L.P. d/b/a Presbyterian Hospital of Denton (Presbyterian) appeals the denial of its motion to dismiss filed pursuant to Texas Civil Practice and Remedies Code section 74.351(b).  See Tex. Civ. Prac. & Rem. Code Ann. § 74.351 (Vernon 2011).  Presbyterian asserts that the suit filed against it by Appellee Amanda Coffman was a health care liability claim, subject to the requirements of chapter 74 of the civil practice and remedies code.  Because we agree with Presbyterian that Coffman’s claim is a health care liability claim, we reverse the trial court’s order, render judgment dismissing Coffman’s claims against Presbyterian, and remand the case for a determination by the trial court of costs and attorney’s fees to be awarded to Presbyterian.

Background

Coffman sought treatment at Presbyterian on November 5, 2007.  As part of her treatment, she submitted a urine sample for testing.  Presbyterian staff released the laboratory report on the sample to the University of North Texas Police Department, who then released it to the University of North Texas, where Coffman was a student.  The laboratory report indicated a violation of the school’s code of student conduct, and Coffman was suspended and removed from student housing.

Coffman claims the release of her test results was negligent and a violation of section 159.002 of the occupations code, which designates medical records as confidential and privileged.  See Tex. Occ. Code Ann. § 159.002 (Vernon 2004).  Coffman filed suit against Presbyterian and the University of North Texas.  The University is not a party to this appeal.

Approximately five months after Coffman filed her petition, Presbyterian moved for dismissal of Coffman’s claims against it, arguing that Coffman failed to timely serve an expert report as required by chapter 74 of the civil practice and remedies code, also known as the Texas Medical Liability Act (TMLA).  See Tex. Civ. Prac. & Rem. Code Ann. § 74.351.  Coffman argued that a report is unnecessary because the TMLA only applies to health care liability claims and her claims are not health care liability claims.  The trial court denied Presbyterian’s motion to dismiss.  Presbyterian filed this appeal.

Standard of Review

Although appellate courts review a trial court’s decision to grant or deny a motion to dismiss for failure to timely serve a section 74.351(a) expert report for an abuse of discretion, see Jernigan v. Langley, 195 S.W.3d 91, 93 (Tex. 2006), the issue presented here requires a determination of whether the TMLA applies to Coffman’s claims.  We therefore review the applicability of the TMLA de novo.  See Marks v. St. Luke’s Episcopal Hosp., 319 S.W.3d 658, 663 (Tex. 2010); Fudge v. Wall, 308 S.W.3d 458, 460 (Tex. App.—Dallas 2010, no pet.).

Whether a claim is a health care liability claim depends on the underlying nature of the claim being made.  Garland Cmty. Hosp. v. Rose, 156 S.W.3d 541, 543 (Tex. 2004).  A party may not avoid the requirements of the TMLA through artful pleading.  Diversicare Gen. Partner, Inc. v. Rubio, 185 S.W.3d 842, 854 (Tex. 2005); Garland Cmty. Hosp., 156 S.W.3d at 543.  Courts must look to the act or omission that forms the basis of the complaint to determine whether it is either an inseparable part of the rendition of health care services or based on a breach of the standard of care applicable to health care providers.  Garland Cmty. Hosp., 156 S.W.3d at 544.  If the factual allegations are related to medical treatment provided by the defendant and constitute an inseparable part of the defendant's rendition of medical services, then the plaintiff’s claim is a health care liability claim subject to the requirements of the TMLA.  Marks, 319 S.W.3d at 664.

Discussion

The sole issue before us is whether a claim for the wrongful release of medical information is a health care liability claim under the TMLA.  See Tex. Civ. Prac. & Rem. Code Ann. §§ 74.001–.507 (Vernon 2011).  If it is a health care liability claim, Coffman was required to serve an expert report within 120 days of filing her original petition.  See id. § 74.351.  The TMLA requires the dismissal of the claim if a report is not served, and the statute does not grant the court the ability to offer an extension for failing to serve a report within the statutory timeframe.  See Maris v. Hendricks, 262 S.W.3d 379, 384 (Tex. App.—Fort Worth 2008, pet. denied) (noting that statutory extension to cure a deficient report does not apply when no report is served).  The parties agree that if it is not a health care liability claim, Coffman was not required to serve such a report.

Coffman argues that no report is necessary because she filed a common law claim of negligence and a claim under the occupations code.  As we stated above, we are required to look at the underlying act or omission forming the basis of the complaint.  See Garland Cmty. Hosp., 156 S.W.3d at 543–44.  If the claim falls under the definition of a health care liability claim, it is subject to the TMLA, regardless of how it was pleaded.  Id. at 544.


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TTHR, LP, D/B/A Presbyterian Hospital of Denton v. Amanda Coffman, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tthr-lp-dba-presbyterian-hospital-of-denton-v-aman-texapp-2011.