WHITE v. HENRY COUNTY MEMORIAL HOSPITAL D/B/A CLINTON HOUSE REHABILITATION AND HEALTHCARE CENTER

CourtDistrict Court, S.D. Indiana
DecidedAugust 12, 2025
Docket1:24-cv-00843
StatusUnknown

This text of WHITE v. HENRY COUNTY MEMORIAL HOSPITAL D/B/A CLINTON HOUSE REHABILITATION AND HEALTHCARE CENTER (WHITE v. HENRY COUNTY MEMORIAL HOSPITAL D/B/A CLINTON HOUSE REHABILITATION AND HEALTHCARE CENTER) is published on Counsel Stack Legal Research, covering District Court, S.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
WHITE v. HENRY COUNTY MEMORIAL HOSPITAL D/B/A CLINTON HOUSE REHABILITATION AND HEALTHCARE CENTER, (S.D. Ind. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

CYNTHIA WHITE Individually and as ) Administrator of the Estate of IRIS ) LONGSTER, Deceased, ) ) Plaintiff, ) ) v. ) No. 1:24-cv-00843-JRS-MKK ) HENRY COUNTY MEMORIAL HOSPITAL ) D/B/A CLINTON HOUSE ) REHABILITATION AND HEALTHCARE ) CENTER, ) FRANKFORT REHABILITATION AND ) HEALTHCARE CENTER, LLC, ) CLINTON HOUSE REHABILITATION ) AND HEALTHCARE LLC, ) CASTLE INDIANA MANAGEMENT LLC, ) ) Defendants. )

Order on Motion to Dismiss

Cynthia White brings this 42 U.S.C. § 1983 suit on behalf of herself and her deceased mother, Iris Longster, alleging that Defendants violated the Federal Nursing Home Reform Act1 after Longster died from a urinary tract infection contracted while she was a resident at Defendant Clinton House. (See generally Second Am. Compl., ECF No. 50.) Now before the Court is Defendants' motion to dismiss White's Second Amended Complaint for lack of subject-matter jurisdiction

1 White also alleges violations of the 1987 Omnibus Budget Reconciliation Act, the overarching legislation that contains the Federal Nursing Home Reform Act, as well as 42 C.F.R. § 483, the applicable implementing regulations. and for failure to state a claim. (ECF No. 58.) For the reasons outlined below, Defendants' motion is granted in part and denied in part. I. Legal Standard

"A motion to dismiss under Rule 12(b)(1) tests the jurisdictional sufficiency of the complaint, accepting as true all well-pleaded factual allegations and drawing reasonable inferences in favor of the plaintiffs." Bultasa Buddhist Temple of Chi. v. Nielsen, 878 F.3d 570, 573 (7th Cir. 2017) (citing Ezekiel v. Michel, 66 F.3d 894, 897 (7th Cir. 1995)). A 12(b)(6) motion to dismiss for failure to state a claim upon which relief can be granted challenges "the legal sufficiency of a complaint" under Rule 8(a)'s standards.

Gunn v. Cont'l Cas. Co., 968 F.3d 802, 806 (7th Cir. 2020). Under Rule 8(a), a complaint must contain a short and plain statement showing that the pleader is entitled to relief. Fed. R. Civ. P. 8(a)(2). A claim is facially plausible if it "pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged." Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009).

When considering a motion to dismiss for failure to state a claim, courts "take all the factual allegations in the complaint as true," and draw all reasonable inferences in the plaintiff's favor. Iqbal, 556 U.S. at 678; Roberts v. City of Chicago, 817 F.3d 561, 564 (7th Cir. 2016). A complaint is not required to identify legal theories, and "specifying an incorrect legal theory is not a fatal error." Rabe v. United Air Lines, Inc., 636 F.3d 866, 872 (7th Cir. 2011). Courts need not, however, accept the truth of legal conclusions, and "[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice." Iqbal, 556 U.S. at 678. "Rule 12(b)(6) authorizes a court to dismiss a claim on the basis of a dispositive issue

of law," meaning the Rule's scope is not limited to claims which are "obviously unsupportable." Neitzke v. Williams, 490 U.S. 319, 326–27 (1989). II. Facts At the motion to dismiss stage, all well-pleaded factual allegations contained in Plaintiff's Complaint are taken as true. Iqbal, 556 U.S. at 678. Iris Longster was admitted to Defendant Clinton House Rehabilitation and Healthcare Center for long-term skilled nursing services in September of 2020, at the

age of 89. The remaining Defendants "owned, managed, operated, supervised, and/or staffed" Defendant Clinton House. (Second Am. Compl. ¶ 17, 19, 21, ECF No. 50.) Longster had a plethora of pre-existing conditions before her admission to Clinton House, and her family informed the nursing home that Longster was prone to urinary tract infections. (Id. ¶ 27, 30.) While a resident at Clinton House, Longster suffered at least five falls, as well as a rash and excoriation of her labia in May of 2022,

allegedly due to Clinton House staff failing to regularly change her. (Id. ¶ 28, 29, 31.) On January 3, 2024, Longster was admitted to the hospital with a UTI and accompanying sepsis. (Id. ¶ 32.) She passed away on January 10, 2024, from her infections. (Id. ¶ 33.) III. Discussion The central issue in this case is whether the relevant provisions of the Federal Nursing Home Reform Act ("FNHRA"), codified at 42 U.S.C. § 1396r, create private rights enforceable under 42 U.S.C. § 1983.

White alleges violations of 42 U.S.C. § 1396r(c)(1)(A)(v)(I) and § 1396r(c)(1)(A)(i). Defendants argue that these FNHRA provisions do not create rights enforceable by individuals under § 1983, but rather lay out the requirements with which nursing homes must comply to receive federal funding. Defendants further contend that White's claims are run-of-the-mill medical malpractice claims governed by Indiana's Medical Malpractice Act ("MMA"); that White is bound by the procedural requirements of the MMA; and that this Court lacks subject-matter jurisdiction over

White's claims. (See generally Br. Supp. Mot. Dismiss, ECF No. 60.) In response, White argues that the Supreme Court's recent decision in Health and Hospital Corporation of Marion County v. Talevski, 599 U.S. 166 (2023), held that FNHRA creates a private right of action enforceable under § 1983; thus, according to White, the Court has subject-matter jurisdiction over this case under its federal question jurisdiction. (Br. Opp'n Mot. Dismiss 11-13, ECF No. 65.)

As a preliminary matter, state administrative exhaustion requirements are not jurisdictional in federal court. "[S]tate law cannot enlarge or contract federal jurisdiction." Thompson v. Cope, 900 F.3d 414, 425 (7th Cir. 2018) (quoting Jarrard v. CDI Telecom., Inc., 408 F.3d 905, 909 n.3 (7th Cir. 2005)). Even though "Indiana courts speak in terms of subject-matter jurisdiction when dismissing claims that are subject to the Medical Malpractice Act but have not gone through the medical review panel process," that characterization is irrelevant here, and the Court's analysis proceeds solely under Rule 12(b)(6). Id. Thus, the Court considers only whether White has stated a claim upon which relief can be granted.

In addition to their position that FNHRA does not confer a private right of action, the Defendants make several other arguments in support of dismissal; the Court addresses each in turn. i.

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Bluebook (online)
WHITE v. HENRY COUNTY MEMORIAL HOSPITAL D/B/A CLINTON HOUSE REHABILITATION AND HEALTHCARE CENTER, Counsel Stack Legal Research, https://law.counselstack.com/opinion/white-v-henry-county-memorial-hospital-dba-clinton-house-rehabilitation-insd-2025.