Reddic v. E. Tex. Med. Ctr. Reg’l Health Care Sys.
No. 14-0333
Case summary written by Ashleigh Hammer, Staff Member.
Louisa Reddic, while visiting East Texas Medical Center, slipped and fell on a floor mat between the hospital’s main entrance and the front desk. Reddic sued the hospital on a premises liability theory. The hospital responded by filing a motion to dismiss, asserting that Reddic’s claim was a health care liability claim (HCLC) under the Texas Medical Liability Act (the Act) and that Reddic failed to serve an expert report as required under the Act’s provisions.
Under the Act, a safety standards based HCLC is a cause of action against a health care provider for a claimed departure from accepted standards of safety, which proximately results in injury to a claimant. In this case, the trial court denied the hospital’s motion, finding that no HCLC claim existed, but the court of appeals reversed, concluding that the care of the floor in an area frequented by patients had an indirect relationship to the provision of healthcare that is sufficient to satisfy, and implicate, the safety provision of the Act.
On appeal, the Supreme Court of Texas relied on a factually similar case that the Court had addressed shortly after the court of appeals issued its opinion. In Ross v. St. Luke’s Episcopal Hospital, the Court held that a safety standards based claim against a healthcare provider is an HCLC claim only if a substantive nexus exists between the safety standards allegedly violated and the provision of healthcare.
The Court also set forth a list of non-exclusive factors for analyzing whether a substantive nexus exists: (1) did the defendant’s alleged negligence occur in the course of the defendant’s performance of tasks with the purpose of protecting patients from harm; (2) did the injuries occur in a place where patients might be during the time they were receiving care; (3) was the claimant in the process of seeking or receiving health care at the time of injury; (4) was the claimant providing or assisting in providing healthcare at the time of injury; (5) is the alleged negligence based on safety standards arising from professional duties owed by the healthcare provider; (6) if an instrumentality was involved in the defendant’s alleged negligence, was it a type used in providing health care; and (7) did the alleged negligence occur in the course of the defendant’s taking action or failing to take action necessary to comply with safety-related requirements set for health care providers by governmental or accrediting agencies.
In this case, the hospital first argued that Ross was inapplicable, but the Court disagreed, noting the immense factual similarities between this case and Ross. Anticipating the applicability of Ross, the hospital then referenced four Ross factors that it believed evidence the substantial nexus sufficient to classify Reddic’s claim as an HCLC: (1) the hospital’s alleged negligence was related to protecting patients from harm; (2) the injury occurred in a location where patients might be located; (3) the alleged negligence is based on safety standards arising from professional duties owed by the hospital as a health care provider; and (4) the alleged negligence occurred in connection with a failure to take action necessary to comply with governmental safety requirements.
The Court disagreed, finding that none of the Ross factors were implicated in this case. Specifically, the Court held that the first two factors were not founded in the record because something more than the patients’ mere presence in a hospital was required to implicate the hospital’s obligation to protect persons who required medical care. As to the second factors, the Court recognized that while the hospital was obligated to comply with general safety standards set by governmental agencies, the record did not show that these generally applicable regulations had a substantial enough relationship to the standards underlying Reddic’s claim—the hospital’s failure to maintain safe floor mats.
In all, the Court concluded that the record in this case did not implicate any of the Ross factors; thus, there was no substantive relationship between the provision of health care and the standards that the hospital allegedly breached. The Court reversed the decision of the court of appeals and remanded to the trial court for further proceedings.