Justia Health Law Opinion Summaries

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Carlos Esteras and Raphael Frias were convicted of fentanyl trafficking charges and appealed their sentences, arguing that the district court erred in calculating their respective Guidelines ranges. Esteras contended that the district court wrongly calculated his base offense level by applying a two-level increase for maintaining a premises for narcotics trafficking and declining to apply a two-level reduction for being a minor participant in the trafficking scheme. He also argued that the district court wrongly applied a two-point increase to his criminal history score after finding that he was on parole at the time of the offense. Frias argued that the district court erred in applying the two-level premises enhancement and a four-level increase for being an organizer or leader of the scheme, and failed to adequately consider his mitigating evidence in declining to vary downwards.The United States District Court for the Northern District of New York had sentenced Esteras to 84 months' imprisonment and Frias to 135 months' imprisonment. The court had applied several sentencing enhancements, including a two-level enhancement for maintaining a premises for narcotics trafficking and a four-level enhancement for being an organizer or leader of the scheme.The United States Court of Appeals for the Second Circuit affirmed each of the district court’s sentencing decisions except its application of the organizer or leader enhancement to Frias. The court affirmed Esteras’s sentence and vacated and remanded Frias’s sentence for further proceedings consistent with its opinion. The court found that Esteras's home qualified for the stash-house enhancement and that he was not a minor participant in the conspiracy. The court also found that Esteras was on parole when he committed his offenses, warranting a two-point increase to his criminal history score. However, the court found that Frias did not qualify as an organizer or leader under the Guidelines, warranting a remand for further proceedings. View "United States v. Frias" on Justia Law

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The case revolves around an employment discrimination suit filed by Dr. Tara Loux against her former employers, BayCare Medical Group and St. Joseph’s Hospital. Dr. Loux sought to discover BayCare’s internal documents about the performance of other doctors who were not fired despite also committing errors. BayCare objected to disclosing certain documents, such as its “quality files” and “referral logs,” arguing that they were privileged under the Patient Safety and Quality Improvement Act of 2005. The Act creates a statutory privilege for work product prepared for or reported to patient safety organizations.The district court ordered BayCare to produce the disputed documents, concluding that the Act does not privilege documents if they have a “dual purpose,” only one of which relates to making reports to a patient safety organization. The court held that these documents were not privileged because BayCare used information in the documents for other purposes, such as internal safety analysis and peer review.The United States Court of Appeals for the Eleventh Circuit disagreed with the district court's interpretation of the Act. The appellate court found that the district court had applied an incorrect "sole purpose" standard to assess whether BayCare’s quality files and referral logs fell under the privilege. The court held that the Act does not require that privileged information be kept solely for provision to a Patient Safety Organization. The court granted BayCare's petition for a writ of mandamus, directing the district court to vacate its orders compelling the disclosure of the privileged documents and reconsider BayCare’s assertion of privilege consistent with the appellate court's opinion. View "In re: Baycare Medical Group, Inc." on Justia Law

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The case involves D.K., a patient diagnosed with an unspecified schizophrenia spectrum and other psychotic disorders, who was found incompetent to stand trial and committed to the Department of State Hospitals (DSH) by the Orange County Superior Court. After D.K.'s transfer to Napa State Hospital, DSH filed a petition for an interim order to compel involuntary medication of D.K. with antipsychotic medication. An administrative law judge (ALJ) conducted an evidentiary hearing and ordered D.K. involuntarily medicated from January 17, 2023, to February 7, 2023. D.K. filed a petition for a writ of administrative mandate with the Napa County Superior Court, challenging the medication order. The superior court denied her petition, concluding D.K. was not entitled to writ review.The Court of Appeal of the State of California First Appellate District Division Three found that D.K.'s appeal was moot because the order had expired and no meaningful relief could be effectuated through review of that order. However, the court exercised its discretion to address D.K.'s appeal of the superior court's finding that the statutory scheme of section 1370 precluded her from filing a writ of administrative mandamus to challenge the medication order. The court concluded that both the significant liberty interests at issue and the language of section 1370 support D.K.'s right to seek writ review. The court reversed the superior court's holding that D.K. was not entitled to writ review. However, it dismissed as moot D.K.'s challenge to the court's finding that substantial evidence supported the involuntary medication order, so it did not remand the case for further proceedings. View "D.K. v. Office of Admin. Hearings" on Justia Law

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The case involves a patent infringement dispute between Copan Italia S.p.A. and Copan Diagnostics Inc. (collectively, “Copan”) and Puritan Medical Products Company LLC and its affiliated companies (collectively, “Puritan”). Copan, the holder of several patents on flocked swabs used for collecting biological specimens, filed a patent infringement complaint against Puritan in the District of Maine. Puritan, in response, filed a partial motion to dismiss, claiming immunity under the Pandemic Readiness and Emergency Preparedness Act (“PREP Act”) for a portion of its accused product.The District Court for the District of Maine denied Puritan's motion to dismiss. The court found that Puritan had not shown, as a factual matter, that its flocked swabs were “covered countermeasures” under the PREP Act. The court also granted Puritan’s motion to amend its answer, allowing it to assert PREP Act immunity as a defense, subject to further argument.Puritan appealed the decision to the United States Court of Appeals for the Federal Circuit. However, the appellate court found that it lacked jurisdiction to review the case. The court reasoned that the district court's denial of Puritan's motion to dismiss did not conclusively determine any issue, which is a requirement for the application of the collateral order doctrine. The court suggested that the district court may wish to structure the litigation in a manner that could allow it to make a conclusive determination on Puritan’s PREP Act immunity defense before the case proceeds any further. The appeal was dismissed due to lack of jurisdiction. View "COPAN ITALIA SPA v. PURITAN MEDICAL PRODUCTS COMPANY LLC " on Justia Law

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The case revolves around John Doyle, who was charged with crimes stemming from a domestic dispute. In August 2019, the trial court ordered Doyle to undergo a competency evaluation, and his mental health and medical records were provided to the Office of the Forensic Examiner (OFE). The court specified that these records could only be used to determine competency and not for any other proceeding without a court order. The OFE concluded that Doyle was not competent to stand trial but could be restored to competence with appropriate treatment. However, an independent examiner concluded that Doyle was unlikely to be restored to competency. In August 2021, the OFE re-evaluated Doyle and concluded that he had not been restored to competency and was dangerous to himself or others.The trial court had previously ruled that Doyle's medical and mental health records were exempt from the physician-patient and psychotherapist-patient privileges, allowing the State to release these records to a physician designated by the State for assessing the appropriateness of involuntary commitment. Doyle appealed this decision, arguing that the court erred in ruling that his records were exempt from these privileges.The Supreme Court of New Hampshire vacated the trial court's decision and remanded the case. The Supreme Court found that the trial court erred in determining that Doyle's medical and mental health records were exempt from statutory privileges under RSA 135:17-a, V. The court concluded that these records were privileged under RSA 329:26 and RSA 330-A:32, and the trial court erred in determining that they were exempt from these privileges. The case was remanded for further proceedings to determine whether there were grounds for disclosing the privileged information. View "State v. Doyle" on Justia Law

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The case revolves around Anna Lange, a transgender woman employed by the Houston County Sheriff's Office in Georgia. Lange was diagnosed with gender dysphoria in 2017 and her healthcare providers recommended a treatment plan that included hormone therapy and gender-affirming surgery. In 2018, her healthcare providers determined that a vaginoplasty was medically necessary. However, Lange's request for coverage was denied based on the health insurance plan's exclusion of services and supplies for sex change and/or the reversal of a sex change. Lange filed claims against Houston County with the Equal Employment Opportunity Commission and subsequently sued Houston County and the Sheriff of Houston County in the Middle District of Georgia.The district court granted summary judgment to Lange on the Title VII claim, finding the Exclusion facially discriminatory as a matter of law. The Title VII claim then proceeded to trial, and a jury awarded Lange $60,000 in damages. After trial, the district court entered an order declaring that the Exclusion violated Title VII and permanently enjoined the Sheriff and Houston County from any further enforcement or application of the Exclusion.The United States Court of Appeals for the Eleventh Circuit affirmed the district court's decision. The court held that a health insurance provider can be held liable under Title VII of the Civil Rights Act of 1964 for denying coverage for gender-affirming care to a transgender employee because the employee is transgender. The court also held that Houston County is liable under Title VII as an agent of the Sheriff's Office. The court affirmed the district court's order permanently enjoining Houston County and the Sheriff from further enforcement or application of the Exclusion. View "Lange v. Houston County, Georgia" on Justia Law

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The case involves a wrongful death claim filed by Judith Rygwall, the mother of Amy Rygwall, against ACR Homes, Inc. Amy, a profoundly vulnerable woman with intellectual and physical disabilities, was under the care of ACR Homes. On New Year's Eve 2015, Amy aspirated (inhaled food into her lungs) and began showing signs of respiratory distress. A member of ACR's staff was informed of these signs but did not seek immediate emergency care for Amy. Instead, she searched online for an urgent care clinic that accepted Amy's insurance with the shortest wait time. Amy's condition worsened, and she died 13 days later from related complications. Rygwall filed a wrongful-death action, asserting that ACR should have immediately called 911 upon learning of Amy's respiratory distress and that failure to do so caused Amy's death.ACR moved for summary judgment on the issue of causation. The district court granted ACR's motion, and the court of appeals affirmed. The district court concluded that Rygwall did not establish that Amy would not have died even if she had received emergency care soon after she exhibited respiratory distress and aspirated after lunch at Rise. The court of appeals agreed, reasoning that Rygwall's expert's report did not explain how Amy's treatment would have progressed had she been seen sooner or how immediate treatment would have prevented her condition from becoming fatal.The Supreme Court of Minnesota reversed the decision of the court of appeals and remanded the case to the district court for further proceedings. The Supreme Court held that Rygwall raised a genuine issue of material fact as to whether ACR caused her daughter's death. The court concluded that based on the record, a reasonable jury could find in Rygwall's favor on the issue of causation, and therefore summary judgment for ACR was inappropriate. View "Rygwall vs. ACR Homes, Inc." on Justia Law

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The case revolves around the death of Skyler A. Womack (Skyler) at Silverscreen Healthcare, Inc., a skilled nursing facility. Skyler's parents, Jonie A. Holland (Holland) and Wayne D. Womack (Wayne), filed a lawsuit against Silverscreen, alleging dependent adult abuse and negligence on behalf of Skyler, as well as their own claim for wrongful death. Silverscreen moved to compel arbitration of the entire complaint based on an arbitration agreement between Skyler and Silverscreen.The Superior Court of Los Angeles County granted Silverscreen’s motion to compel arbitration for the survivor claims but denied the motion for the wrongful death cause of action. The court reasoned that the parents did not have an enforceable arbitration agreement with Silverscreen. The court's decision was heavily influenced by the case Avila v. Southern California Specialty Care, Inc.Silverscreen appealed the decision to the Court of Appeal of the State of California, Second Appellate District. The appellant argued that, according to Ruiz v. Podolsky, the parents are bound by the arbitration agreement signed by Skyler, and therefore, the parents’ wrongful death claim should be subject to arbitration. The appellate court agreed with Silverscreen, stating that Ruiz governs this matter. Consequently, under Ruiz and Code of Civil Procedure section 1295, the parents’ wrongful death claim must go to arbitration along with Skyler’s survivor claims. The court reversed the trial court's decision and remanded the case with directions. View "Holland v. Silverscreen Healthcare, Inc." on Justia Law

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Heather Walters, a Direct Support Professional at Brandi’s Hope Community Services, a long-term care facility for people with intellectual and developmental disabilities, noticed that a resident had been physically abused. She attempted to report the incident to her supervisors but received no response. Walters then took a photograph of the resident's injuries and shared it with a former coworker. After an internal investigation, Walters was fired for violating company policy and HIPAA regulations by taking and sharing the photograph. Walters filed a lawsuit against Brandi’s Hope and its CEO, Danny Cowart, for retaliatory discharge and malicious interference with employment.The County Court of Lee County found in favor of Walters, awarding her $100,000 in damages. The defendants appealed to the Lee County Circuit Court, which affirmed the lower court's decision. The defendants then appealed to the Court of Appeals, which reversed the lower courts' decisions, finding that the Mississippi Vulnerable Persons Act and the public policy exception established in McArn v. Allied Bruce-Terminix Co., Inc. were in conflict.The Supreme Court of Mississippi reversed the Court of Appeals' decision, finding no conflict between the Mississippi Vulnerable Persons Act and the public policy exception established in McArn. The court held that Walters was eligible to claim wrongful termination under McArn, as she was fired for reporting illegal activity. The court affirmed the jury's verdict that Brandi’s Hope terminated Walters because she reported the abuse. The case was remanded to the County Court of Lee County for further proceedings. The Court of Appeals' decision to render judgment in favor of Cowart on the malicious-interference-with-employment claim was not reviewed and thus stands. View "Brandi's Hope Community Services, LLC v. Walters" on Justia Law

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Dr. Randy Lamartiniere, an internal medicine doctor, was convicted of twenty counts of unlawful distribution of controlled substances. Lamartiniere had been practicing medicine for approximately thirty years and had a growing number of chronic pain patients. Concerns arose about his management of opioid and narcotic prescriptions and his inability to maintain timely patient records, leading to his termination from a clinic. He then opened his own practice, where a significant portion of his patients were pain management patients. The Drug Enforcement Administration (DEA) launched an investigation into his prescription practices, which included undercover agents posing as chronic pain patients. Lamartiniere was subsequently charged with twenty-eight counts of unlawful distribution of Schedule II controlled substances.At trial, the Government presented evidence from Lamartiniere’s former patients, undercover agents, and expert witnesses. Lamartiniere testified in his own defense, arguing that he was genuinely trying to treat his patients' legitimate medical conditions. The jury convicted Lamartiniere on twenty counts, and he was sentenced to 180 months per count, to run concurrently. Lamartiniere appealed, challenging the jury instructions and the sufficiency of the evidence supporting his convictions. The United States Court of Appeals for the Fifth Circuit affirmed the convictions, finding no reversible error. View "United States v. Lamartiniere" on Justia Law