Justia Health Law Opinion Summaries

Richard Shreves, while incarcerated at the Montana State Prison, received medical care and subsequently filed a complaint against Dr. Paul Rees with the Board of Medical Examiners at the Montana Department of Labor and Industry (DLI). The Correctional Health Care Review Team (CHCRT) reviewed the complaint and found no violation of law or practice rules by Dr. Rees, leading to the closure of the complaint without forwarding it to the Board of Medical Examiners. Shreves then petitioned for judicial review, challenging the CHCRT's decision and the lack of detailed findings in their response.The First Judicial District Court dismissed Shreves's petition, concluding that he lacked standing. The court reasoned that the CHCRT process did not implicate Shreves's legal rights, as it was designed to screen complaints for potential disciplinary action against the healthcare provider, not to adjudicate the complainant's rights.The Supreme Court of the State of Montana affirmed the District Court's dismissal. The court held that Shreves did not have standing to petition for judicial review because the statute governing the CHCRT process did not authorize judicial review at the behest of the complainant. The court also found that Shreves's constitutional challenge to the CHCRT's authority did not confer standing, as he lacked a personal stake in the outcome. Additionally, the court determined that any alleged mishandling of filings by the District Court did not affect the outcome, as the legal conclusions regarding standing were correct. View "Shreves v. Montana Dept. of Labor" on Justia Law

The case involves a challenge to two Montana laws, HB 544 and HB 862, and a rule adopted by the Montana Department of Public Health and Human Services (DPHHS) regarding Medicaid funding for abortions. The plaintiffs, including Planned Parenthood of Montana and other healthcare providers, argue that these provisions infringe on the constitutional rights of their patients by imposing restrictions on Medicaid coverage for abortions. Specifically, the laws and rule bar Medicaid from covering abortions provided by non-physicians, require prior authorization for abortion services, and limit Medicaid coverage to abortions deemed "medically necessary" under a restrictive definition.The First Judicial District Court of Lewis and Clark County issued a preliminary injunction to halt the enforcement of HB 544, HB 862, and the DPHHS rule. The court found that the plaintiffs were likely to succeed on the merits of their claims, which included violations of the right to privacy and equal protection under the Montana Constitution. The court applied strict scrutiny, determining that the laws and rule were not narrowly tailored to serve a compelling state interest. The court also found that the plaintiffs would suffer irreparable harm without the injunction and that the balance of equities and public interest favored granting the injunction.The Montana Supreme Court reviewed the case and affirmed the District Court's decision to grant the preliminary injunction. The Supreme Court agreed that the plaintiffs were likely to succeed on the merits, as the challenged provisions infringed on the fundamental right to privacy and equal protection. The court held that the state failed to demonstrate that the laws and rule were narrowly tailored to address a medically acknowledged, bona fide health risk. The Supreme Court also found that the plaintiffs would suffer irreparable harm without the injunction and that the balance of equities and public interest supported maintaining the injunction. View "Planned Parenthood v. State" on Justia Law

O.L.K. was admitted to Montana State Hospital in January 2022 following a disturbance at a mental health treatment center. The petition for involuntary commitment was based on an evaluation by Michale McLean, LCSW, which included observations and reports from medical staff and law enforcement. O.L.K. had been brought to the hospital twice in one day for aggressive behavior, including threatening his therapist and threatening to burn down the treatment center. During his second hospital visit, he made several threatening statements, including threats to kill someone.The Fourth Judicial District Court, Missoula County, appointed Shannon McNabb, a Licensed Clinical Professional Counselor, to evaluate O.L.K. McNabb testified that O.L.K. exhibited disorganized and delusional behavior and diagnosed him with Bipolar I disorder. She relied on various records, including the St. Patrick’s Report, and testified about O.L.K.’s threats and delusional statements. The District Court overruled hearsay objections raised by O.L.K.’s attorney, admitting the St. Patrick’s Report under the medical records exception. The court found that O.L.K. presented an imminent risk to others and committed him to Montana State Hospital for up to 90 days.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court’s decision. The Supreme Court held that while the District Court erred in admitting the St. Patrick’s Report as a hearsay exception, there was substantial admissible evidence from McNabb’s testimony to support the finding of an overt act. The court concluded that O.L.K.’s statements to McNabb, which included threats to kill someone, were sufficient to demonstrate an imminent threat of injury to others. The decision to commit O.L.K. was therefore upheld. View "In re O.L.K." on Justia Law

Dr. Thomas C. Weiner, an oncologist, had his medical staff membership and clinical privileges revoked by St. Peter’s Health (SPH) in 2020. Prior to this, Weiner had initiated litigation (Weiner I) against SPH, alleging wrongful termination, civil conspiracy, and due process violations. During Weiner I, he requested an administrative hearing under SPH Bylaws, leading SPH to seek a stay, which was denied. Weiner was allowed to amend his complaint once but was denied a second amendment to include claims related to the administrative review process.The First Judicial District Court, Lewis and Clark County, denied Weiner’s motion to file a second amended complaint in Weiner I, citing untimeliness and potential prejudice to SPH. Subsequently, Weiner filed a new lawsuit (Weiner II) in June 2022, asserting claims similar to those he sought to add in Weiner I. SPH moved to dismiss Weiner II, arguing it was an impermissible collateral attack and constituted claim-splitting. The District Court dismissed Weiner II based on res judicata, reasoning that Weiner could have included his new claims in Weiner I and that the denial of his motion to amend was a final judgment on the merits.The Supreme Court of the State of Montana reviewed the case and affirmed the dismissal of Weiner II, but on different grounds. The court held that the District Court erred in applying res judicata because the denial of the motion to amend in Weiner I was not a final judgment on the merits. However, the Supreme Court concluded that Weiner II was properly dismissed under the doctrine of claim-splitting, which prevents parties from maintaining multiple lawsuits based on the same transaction or series of connected transactions. The court emphasized that claim-splitting aims to promote judicial economy and prevent duplicative litigation. View "Weiner v. St. Peter's Health" on Justia Law

This case involves a class action lawsuit against Logan Health Medical Center ("Logan Health") following a significant data breach of its information technology systems. The breach, which occurred on November 22, 2021, exposed highly sensitive personal identifying information and protected health information of over 200,000 current and former patients and others affiliated with Logan Health. Patricia Tafelski, on behalf of herself and all others similarly situated, filed a complaint against Logan Health. After a series of negotiations, the parties agreed to a settlement of $4.3 million for a common fund. The District Court granted preliminary approval of the proposed settlement on December 6, 2022.The District Court of the Eighth Judicial District, in and for the County of Cascade, granted final approval of the Settlement Agreement, awarded Class Counsel attorney fees, and denied the Objectors’ motion for discovery. The Objectors, Mark Johnson and Tammi Fisher, appealed the order, arguing that the attorney fees of 33.33% of the settlement fund were unreasonable and that their motion for discovery was wrongly denied.The Supreme Court of the State of Montana affirmed the lower court's decision. The court found that the District Court did not abuse its discretion in awarding Class Counsel attorney fees. The court also found that the District Court did not abuse its discretion in denying the Objectors’ motion for discovery. The court noted that the District Court had made adequate findings on each of the factors for determining the reasonableness of attorney fees and that those findings were supported by the record. The court also noted that the District Court had conscientiously considered the nature of the litigation and the interests of the class in denying the Objectors’ motion for discovery. View "Tafelski v. Johnson" on Justia Law

This case involves an appeal against a judgment from the Montana Eighteenth Judicial District Court, Gallatin County, which committed the appellant, G.M., into the custody and care of the Montana State Hospital (MSH) for involuntary mental health treatment. The key issue at hand is whether the District Court erroneously found that G.M. was unable to adequately care for her own basic needs and safety based on hearsay statements made by her husband through the testimony of a court-appointed professional.G.M., aged 66 at the time of the petition for involuntary mental health commitment in 2021, was alleged to be suffering from a diagnosed psychotic mental disorder. G.M.'s husband's statements, along with her own behavior and assessments from mental health professionals, were the basis for the court's decision. G.M.'s counsel repeatedly objected to the court-appointed professional's testimony regarding her husband's out-of-court statements, but these objections were overruled.G.M. testified on her own behalf, denying having a mental disorder or requiring treatment. Despite this, the District Court found that due to her diagnosed schizophrenic and delusional mental disorder, G.M. was “substantially unable to provide for her own basic needs of food, clothing, shelter, health, or safety."On appeal, the Supreme Court of the State of Montana affirmed the judgment of the lower court. The court found that the lower court's decision was not clearly erroneous and was supported by substantial admissible evidence. The court stated that the hearsay statements of G.M.'s husband were admissible under the rules of evidence to explain the underlying rationale for the court-appointed professional person's expert opinion. The court also noted that the judgment was independently supported by the professional person's personal observations and opinions on G.M.'s condition and ability to care for her own needs and safety. View "In re Matter of G.M." on Justia Law

The case involves an appellant, M.T.H., who was arrested for criminal endangerment after he pulled the steering wheel in his mother's vehicle while she was driving. M.T.H. was diagnosed with major depressive disorder and paranoid schizophrenia. Following his arrest, the State filed a petition for M.T.H.'s involuntary commitment to the Montana State Hospital (MSH) for up to three months. The District Court of the Twenty-First Judicial District, Ravalli County, ordered his commitment and authorized MSH to involuntarily administer medications to M.T.H. This led to an appeal to the Supreme Court of the State of Montana.The Supreme Court of Montana had two main issues to consider. The first issue was whether the District Court erroneously determined that a signed waiver constituted a sufficient record to commit M.T.H. The Supreme Court found that M.T.H.'s waiver and the District Court’s order committing him were sufficient to constitute an intentional and knowing waiver under the relevant statute. The court emphasized that the record reflected that M.T.H. understood his procedural rights and had a clear presence of mind to consider his position logically.The second issue was whether the District Court erroneously authorized MSH to administer involuntary medications to M.T.H. The Supreme Court held that the District Court erred in this aspect. It emphasized the importance of due process protections and noted that the State must demonstrate a need for involuntary medication before a court may authorize it. In this case, the State did not make this necessary showing. Therefore, the Supreme Court affirmed the District Court’s decision in part but reversed its decision to authorize involuntary medication for M.T.H. View "In re M.T.H." on Justia Law

The Supreme Court reversed the oral pronouncement issued by the district court waiving Appellant's right to be physically present at his commitment hearing and the findings of fact, conclusions of law, and order of commitment issued by the district court, holding that the court committed reversible error by waiving Appellant's right to physically appear.The State filed a petition for involuntary commitment of Appellant supported by a mental health evaluation. Appellant advised the court that he desired to be present in-person at the commitment hearing. At the time of the hearing, however, counsel represented that he wished to waive Appellant's appearance and instead have him appear via two-way video conferencing due to improper behavior. The district court granted counsel's request and permitted him to appear via two-way video communication. The district court subsequently committed Appellant to the Montana State Hospital and authorized the use of involuntary medication. The Supreme Court reversed, holding that the statutory requirements for waiver of physical presence at the commitment hearing were not met. View "In re J.D.L." on Justia Law

The Supreme Court affirmed in part and remanded in part the order of the district court denying Plaintiffs' application to preliminarily enjoin the State from enforcing House Bill 702, a "vaccination discrimination law," as enacted by the Legislature and signed by the Governor, holding that the district court did not abuse its discretion in declining to issue the preliminary injunction.HB 702, codified as Mont. Code Ann. 49-2-312, was an act "prohibition discrimination based on a person's vaccination status." Plaintiffs sought to preserve their ability to enforce a vaccine mandate on current and prospective employees by bringing this action. The lower court dismissed the complaint, ruling that Plaintiffs failed to satisfy their burden of establishing a prima facie case that they would suffer irreparable harm caused by implantation of the law prior to the final resolution of the case. The Supreme Court remanded in part, holding (1) the court's decision to deny preliminary injunctive relief did not constitute a manifest abuse of discretion; and (2) the court did not manifestly abuse its discretion in denying preliminary injunctive relief prior to final resolution on the merits. View "Netzer v. State" on Justia Law

The Supreme Court reversed the order of the district court committing Appellant to the Montana State Hospital at Warm Springs for a period of up to ninety days, holding that the district court committed reversible error when it allowed a professional person to testify by telephone over Appellant's objection.The State filed a petition for Appellant's involuntary commitment due to her disorganized thinking and confusion. At a hearing on the petition, the State called Amanda Torres, a licensed clinical professional counselor, to testify by telephone due to technical difficulties with courtroom video capabilities. The district court overruled Appellant's rejection and allowed Torres to testify by telephone. Relying on Torres's testimony, the district court concluded that Appellant suffered from a mental disorder and required commitment. The Supreme Court reversed, holding that the district court erroneously overruled Appellant's objection and that the court was statutorily mandated to prohibit Torres's testimony by telephone because it did not satisfy the requirement for two-way audio-video communication and because Appellant objected. View "In re S.E." on Justia Law