Justia Health Law Opinion Summaries

The case involves the Department of Children, Youth, and Families (DCYF) in Rhode Island, which was held in contempt by the Family Court for failing to place a minor, N.D., in a residential facility appropriate for her level of need. N.D., a teenager with severe mental health issues, was under the temporary custody of DCYF. Despite the court's order, DCYF was unable to find an appropriate in-state or out-of-state placement for N.D. due to her high level of need and the lack of available facilities. The Court Appointed Special Advocate (CASA) filed a motion to adjudge DCYF in contempt for this failure.The Family Court found DCYF in contempt, rejecting DCYF's defense that it was unable to comply with the court's order. The court imposed a contempt sanction of $1,000 per day until N.D. was placed in an appropriate facility, with the sanction to be placed in a trust for N.D.'s benefit. DCYF appealed this decision.The Supreme Court of Rhode Island vacated the order of the Family Court. The Supreme Court found that while DCYF was in technical violation of the Family Court's order, it had demonstrated that it was literally unable to comply because an appropriate placement for N.D. was not presently within its power. The court noted the lack of appropriate facilities for girls with N.D.'s level of need in Rhode Island, staffing issues, and an increase in mental health problems among adolescents. The case was remanded to the Family Court for further proceedings. View "In re N.D." on Justia Law

Integra is an accountable-care organization under the Medicare Shared Savings Program (MSSP). RIPCPC is an independent practice association of physicians located in Rhode Island. The plaintiffs (Hayden, King, Corsi) are primary care physicians and operated their own independent practices. Each participated in Integra until 2018, when they terminated their respective agreements upon the sale of their respective independent practices (Integra agreements) and terminated their relationships with RIPCPC. The plaintiffs alleged breach of contract, unjust enrichment, breach of the implied covenant of good faith and fair dealing, conversion, and anticipatory breach/repudiation against Integra and RIPCPC, claiming that Integra and RIPCPC owed plaintiffs certain payments and shared savings for 2017 and 2018.The defendant’s motion to dismiss was granted as to breach of the implied covenant of good faith and fair dealing by RIPCPC and anticipatory breach/repudiation by RIPCPC. RIPCPC then successfully moved to stay the proceedings and compel arbitration as to plaintiffs’ claims against RIPCPC for breach of contract, unjust enrichment, conversion, and declaratory judgment. The Rhode Island Supreme Court held that the hearing justice did not err in granting RIPCPC’s motion to compel arbitration with regard to Hayden’s claims for breach of contract, conversion, and unjust enrichment nor in granting RIPCPC’s motion to compel arbitration with regard to Corsi’s claim for breach of contract but erred in granting RIPCPC’s motion to compel arbitration with regard to Corsi’s claims and King’s claims for conversion and unjust enrichment. View "Hayden v. Integra Community Care Network, LLC" on Justia Law

The Supreme Court affirmed the order of the district court committing Respondent to a residential living facility for adults with developmental disabilities, holding that there was no error or abuse of discretion.The Rhode Island Department of Behavioral Healthcare, Developmental Disabilities and Hospitals filed a petition for civil court certification to retain Respondent, a person with developmental disabilities, in a residential facility. The hearing justice found that Respondent was developmentally disabled and ordered that he reside at a group home. The Supreme Court affirmed, holding (1) Respondent's appeal was timely; and (2) Respondent waived his argument that the district court erred in allowing the admission of testimony regarding Respondent's juvenile conviction, his requirement to register as a sex offender, and other uncharged bad acts committed by Respondent. View "In re J.T." on Justia Law

The Supreme Court affirmed the judgment of the superior court in favor of South County Hospital, Home & Hospice Care of Rhode Island and Emmy Mahoney, M.D. (collectively, Defendants), and dismissing all claims alleged by Plaintiff individually and on behalf of the Guardianship of Joyce C. Willner, holding that the trial justice did not err in dismissing the claims.Plaintiff filed an eight-count complaint against Defendants, individually and as guardian of Joyce Willner, his mother. The trial judge granted Defendants' motions to dismiss and motions for summary judgment, dismissing all claims. The Supreme Court affirmed, holding that the trial justice did not err in (1) dismissing the claims alleged by Plaintiff on behalf of the guardianship because Joyce had no right to be represented by Plaintiff, who was not authorized to practice law; and (2) denying Plaintiff's request to appoint a guardian ad litem. View "Willner v. South County Hospital" on Justia Law

The Supreme Court affirmed the postjudgment order of the family court in favor of Judith Cusick requiring Maurice Cusick to submit to limited genetic testing for the benefit of the parties' minor children, holding that the hearing justice made sufficient findings of fact and did not overlook or misconceive any evidence.Judith, Maurice's former wife, filed her motion for genetic testing after Maurice was diagnosed with a genetic heart condition that poses significant risks that can result in sudden death. The hearing justice granted the motion. Maurice appealed, arguing for the first time that ordering him to submit to genetic testing violated his constitutional rights to privacy and due process. The Supreme Court affirmed, holding (1) Maurice's constitutional challenges were not property before the Court; and (2) the hearing justice's conclusion that genetic testing was in the best interest of the children was supported by the evidence, and the order was both balanced and reasonable. View "Cusick v. Cusick" on Justia Law

The Supreme Court affirmed Defendant’s conviction for first-degree child abuse, holding that the trial justice did not err by requiring a licensed clinical social worker to testify about statements Defendant made to her while seeking mental-health treatment.A dispositive issue on appeal was whether any privilege arising from the Confidentiality of Health Care Information Act, R.I. Gen. Laws 5-37.3, is abrogated by R.I. Gen. Laws 40-11-11. The Supreme Court affirmed, holding (1) section 40-11-11 unambiguously abrogates all privileges that might otherwise attach to communications between any professional person and her patient in situations involving known or suspected child abuse or neglect; and (2) this nullification of such privileges in judicial proceedings includes criminal proceedings. View "State v. LeFebvre" on Justia Law

The Supreme Court quashed the judgment of the superior court that reversed a decision by the Rhode Island Department of Health (DOH) to grant Petitioner’s application for a Health Care Certificate of Need (CON) on the basis that Petitioner’s application did not demonstrate a public need.The Supreme Court disagreed, holding (1) the DOH correctly applied its rules and regulations when it determined that the public need set forth in Petitioner’s application was appropriate; and (2) the DOH relied upon competent evidence for future public need in support of its decision to grant Petitioner’s CON application. View "Endoscopy Associates, Inc. v. Rhode Island Department of Health" on Justia Law

On June 10, 2005, Plaintiff underwent surgery for a tumor in his neck. Analysis of the tumor on the same day revealed it was a form of cancer. Plaintiff alleged he learned he had cancer on June 21, 2005. Plaintiff and his wife filed a medical malpractice action against several doctors and health care facilities for failing to diagnose and treat Plaintiff's cancer. The trial court granted summary judgment in favor of Defendants, holding that the three-year statute of limitations began to run on June 2, 2005, when a separate medical doctor diagnosed the mass in Defendant's neck as a cervical tumor, and had expired before Plaintiffs filed suit on June 9, 2008. The Supreme Court affirmed, holding that when Plaintiff was diagnosed as having a cervical tumor and that diagnosis was shared with Plaintiff, a "reasonable person in similar circumstances" would have discovered that the wrongful conduct of Defendants caused Plaintiff's injuries. View "Bustamante v. Oshiro" on Justia Law

The director of the Department of Mental Health, Retardation and Hospitals (Department) petitioned the superior court for an emergency transfer of Irving Briggs, a sentenced inmate, from the forensic unit of the Eleanor Slater Hospital, where Briggs was receiving mental-health services, back to the Adult Correctional Institutions (ACI) where he had previously been incarcerated. The superior court allowed an emergency transfer in the absence of a full evidentiary hearing, finding that potential harm could occur to others if Briggs were to remain at the forensic unit. After a post-transfer evidentiary hearing, a mental health advocate filed a motion to impose sanctions, alleging that the Department contrived a materially inaccurate set of facts to secure an immediate discharge of Briggs from the hospital. The trial justice declined to find a conspiracy among the Department staff and administration to remove Briggs from the forensic unit at any and all costs. The Supreme Court affirmed, holding (1) the trial justice did not abuse his discretion when it denied to impose sanctions; and (2) Briggs's argument that his emergency transfer to the ACI violated his procedural due process rights was moot. View "In re Briggs" on Justia Law

Pearl Archambault died while in the care of Haven Health Center of Greenville (Haven Health) after a nurse mistakenly administered a lethal overdose of morphine. The administratrix of her estate, Plaintiff, filed a medical malpractice action against Haven Health. Health Haven subsequently filed for Chapter 11 bankruptcy. Thereafter, Plaintiff amended her complaint to add Columbia Casualty Company, the professional liability insurer of Health Haven, as a defendant and asserted two counts against Columbia directly based on R.I. Gen. Laws 27-7-2.4, which permits an injured party to proceed against an insurer when the insured has filed for bankruptcy. The superior court entered default judgment against Haven Health. The court then granted summary judgment in favor of Columbia. The Supreme Court reversed and remanded with instructions to enter judgment against Columbia, holding that the superior court erred in interpreting Rhode Island law and that the insurance contract between Columbia and Health Haven should be construed in Plaintiff's favor. View "Peloquin v. Haven Health Ctr. of Greenville, LLC" on Justia Law