Justia Health Law Opinion Summaries

Articles Posted in Supreme Court of Texas
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The case in question was heard by the Supreme Court of Texas and revolved around the interpretation of the term "psychiatrist" as it applies to the involuntary civil commitment of individuals exhibiting signs of mental illness. The case involved a 34-year-old man, A.R.C., who had exhibited psychotic symptoms and delusional behavior. Two second-year psychiatry residents completed the required "certificates of medical examination for mental illness," as outlined in Tex. Health & Safety Code § 574.009(a). However, a question arose as to whether these residents could be considered psychiatrists under the statute.The Supreme Court of Texas ruled that these residents were indeed psychiatrists, reversing the lower court's judgment. The court determined that the residents, who were licensed under a physician-in-training program and were engaged in specialized psychiatric training, fell within the definition of a physician specializing in psychiatry. The court rejected the argument that only board-certified psychiatrists qualify under the statute, stating that physicians who specialize in psychiatry qualify as psychiatrists under § 574.009(a).The court emphasized that it is the judge, not the physician, who ultimately decides whether involuntary commitment is necessary or lawful. The court also noted that the legislature has the power to amend the qualifications for psychiatrists and other physicians as it sees fit, provided it adheres to the constitutional requirement of competent medical or psychiatric testimony.The Supreme Court of Texas remanded the case to the court of appeals for consideration of A.R.C.'s remaining challenges. View "IN RE A.R.C." on Justia Law

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The Supreme Court of Texas handled a case in which a nurse claimed her employer, Scott & White Memorial Hospital, wrongfully terminated her employment in retaliation for reporting potential child abuse or neglect to the Texas Child Protective Services (CPS), which is considered a protected conduct under Section 261.110(b) of the Texas Family Code.The nurse, Dawn Thompson, had previously received two written reprimands for violating the hospital's personal-conduct policy. On the third occasion, she disclosed a child patient's protected health information to a school nurse without the parents' authorization. This was considered by the hospital as a violation of the Health Insurance Portability and Accountability Act (HIPAA) and a breach of the patient's rights. Consequently, Thompson was terminated.Thompson filed a lawsuit against the hospital, asserting that her termination was in violation of Family Code Section 261.110(b), which protects professionals who report child abuse or neglect in good faith from adverse employment actions.The Supreme Court of Texas ruled that Section 261.110 imposes a "but-for causation" requirement, which means that the protected conduct must be such that without it, the adverse employment action would not have occurred when it did. In this case, the court found that Thompson would have been terminated when she was due to her HIPAA violation, regardless of her report to CPS. Therefore, the court rejected Thompson's retaliation claim and reinstated the trial court's summary judgment in favor of the hospital. View "SCOTT & WHITE MEMORIAL HOSPITAL v. THOMPSON" on Justia Law

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In this case handled by the Supreme Court of Texas, the parents of two children, Kate Cox and Justin Cox, along with their doctor, Dr. Damla Karsan, filed a suit to challenge the enforcement of Texas laws that prohibit abortion. Mrs. Cox was about 20 weeks pregnant with a baby diagnosed with trisomy 18, a serious genetic disorder. The suit sought to apply a medical-necessity exception provided in the Texas law, which allows an abortion if a woman's life is threatened or she faces a serious risk of substantial impairment of a major bodily function due to her pregnancy.The court, in its decision, clarified that the exception to the abortion prohibition is based on the reasonable medical judgment of a doctor, not a court. It was noted that Dr. Karsan presented a "good faith belief" that Mrs. Cox meets the exception's requirements but did not assert that her belief meets the objective standard of "reasonable medical judgment."The court held that judges lack the authority to broaden the statutory exception by interpreting it and held the trial court erred in applying a different, lower standard instead of requiring reasonable medical judgment. The court emphasized that the exception requires a doctor's decision whether a pregnant woman’s complications pose the required risks.The court conditionally granted relief and directed the trial court to vacate the temporary restraining order that had restrained the Attorney General from enforcing the abortion laws against Dr. Karsan and others related to the case, based solely on the verified pleading. The court also noted that nothing in their opinion prevents a physician from acting if, in that physician’s reasonable medical judgment, they determine that the pregnant woman has a life-threatening physical condition. View "IN RE STATE OF TEXAS" on Justia Law

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In this case involving mandates requiring people to wear face masks or other coverings to prevent the spread of COVID-19 the Supreme Court vacated the judgment and opinion of the court of appeals and dismissed this interlocutory appeal, holding that the appeal was moot.In 2021, the City of El Paso obtained a temporary injunction against the enforcement of GA-38, a gubernatorial executive order that prohibited local mask-wearing requirements. The court of appeals affirmed. In 2023, Senate Bill 29, codified as Tex. Health & Safety Code 81.B.001-.004, which provided that a governmental entity may not impose mask-wearing requirement to prevent the spread of COVID-19, went into effect. Further, GA-38 expired. The Supreme Court vacated the court of appeals and dismissed this appeal, holding that no live controversy remained between the parties. View "Abbott v. City of El Paso" on Justia Law

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The Supreme Court dismissed this interlocutory appeal as moot and vacated the judgment of the court of appeals in this case arising from the Covid-19 pandemic, holding that the public interest was best served by vacatur of the court of appeals' opinion and that the State was prevented from challenging on the merits due to mootness.When the San Antonio Independent School District (ISD) required that its employees take a Covid-19 vaccine by October 15 2021, the State sued, seeking a temporary injunction arguing that the vaccine requirement violated a gubernatorial executive order. The district court denied relief. The court of appeals affirmed. The Supreme Court denied the ensuing appeal as moot, holding that neither the enforceability of the ISD's vaccine mandate, which was barred by Senate Bill 29, nor the enforceability of executive order GA-39, which had expired, left a live controversy between the parties. View "State v. San Antonio Independent School District" on Justia Law

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The Supreme Court reversed the judgment of the court of appeals affirming the decision of the trial court appeals denying the Texas Tech University School of Medicine's combined plea to the jurisdiction and summary judgment motion in the underlying unlawful discrimination action, holding that morbid obesity does not qualify as an impairment under the Texas Commission on Human Rights Act (TCHRA) without evidence that it is caused by an underlying physiological disorder or condition.After Plaintiff was dismissed from Texas Tech's medical residency program she brought this complaint alleging that the University dismissed her because of her morbid obesity, which she argued constituted unlawful discrimination under the TCHRA. The University filed a combined plea to the jurisdiction and summary judgment motion, arguing that it was protected under sovereign immunity. The trial court denied the plea and motion, and the court of appeals affirmed. The Supreme Court reversed, holding (1) morbid obesity qualifies as an impairment under the Labor Code only when caused by a physiological disorder or condition; and (2) Plaintiff could not establish that the University regarded her as having an impairment, and Plaintiff failed to show a disability as defined in the Labor Code. View "Tex. Tech University Health Sciences Center - El Paso v. Niehay" on Justia Law

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The Supreme Court vacated the judgment of the court of appeals affirming the trial court's judgment issuing in July 2021 a temporary restraining order prohibiting enforcement of executive order GA-38, holding that this case is remanded for further proceedings consistent with this Court's opinion in Abbott v. Harris County, 22-0124, which concerned the scope and constitutionality of the Governor's authority under the Disaster Act to prohibit local governments from imposing mask requirements.The City of San Antonio and Bexar County jointly filed this lawsuit challenging GA-38, which prohibited local officials from requiring masks in response to the coronavirus epidemic. The district court issued a temporary restraining order prohibiting enforcement of the executive order and then temporarily enjoined the Governor and others from enforcing GA-38 to the extent that such a requirement would interfere with the local official's authority to require masks in government-owed buildings and schools. The court of appeals affirmed the temporary injunction. In light of this Court's decision in Abbott v. Harris County, the Supreme Court vacated the judgment below, holding that remand was required. View "Abbott v. City of San Antonio" on Justia Law

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The Supreme Court held that the Texas Insurance Code does not authorize a private cause of action by a physician against an insurer for payment of claims that accrued prior to 2020 and that Plaintiffs' claims for recovery in quantum merit and for unfair settlement practices failed as a matter of law.In each of the consolidated cases before the Supreme Court, Plaintiffs, groups of emergency medicine doctors outside of an insurer's provider network, brought suit against Defendant, the insurer, alleging that it did not pay them at the usual and customary rates for treating its insureds. Defendant moved for dismissal under Fed. R. Civ. P. 12(b)(6) for failure to state a claim. The district court granted the motion with respect to Plaintiff's implied contract and quantum merit claims and with respect to claims brought under the Emergency Care Statutes. On appeal, the court of appeals certified a question to the Supreme Court. The Supreme Court held (1) the Insurance Code does not create a private cause of action for claims under the Emergency Care Statutes; and (2) with respect to one case, the lower courts did not err in dismissing Plaintiffs' quantum merit and unfair settlement practices claims. View "Texas Medicine Resources, LLP v. Molina Healthcare of Texas, Inc." on Justia Law

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The Supreme Court reversed the judgment of the trial court permanently enjoining the Texas Department of State Health Services from enforcing a new Texas law that prohibited the processing and manufacturing of smokable hemp products, holding that Plaintiffs were not entitled to relief.In their complaint, Plaintiffs - Texas-based entities that manufacture, process, distribute, and sell hemp products - argued that Tex. Const. art. I, 19 invalidated the challenged law and sought an injunction prohibiting Defendant from enforcing the law. The trial court declared that Tex. Health & Safety Code 443.202(4) violated the Texas Constitution and that 25 Tex. Admin. Code 300.104 was invalid in its entirety and enjoined Defendant from enforcing the statute or the rule. The Supreme Court reversed, holding that Plaintiffs' complaints did not assert the deprivation of an interest substantively protected by the Texas Constitution's due course clause. View "Texas Department of State Health Services v. Crown Distributing LLC" on Justia Law

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The Supreme Court accepted a certified question from the United States Court of Appeals for the Fifth Circuit by answering that Texas law does not authorize certain state officials to directly or indirectly enforce the state's new abortion restriction requirements.Plaintiffs, who provided and funded abortions and support for women who obtain them in Texas, requested a declaration that Senate Bill 8, the "Texas Heartbeat Act," Tex. Health & Safety Code 171.201-.212, unconstitutionally restricted their rights and injunction prohibiting Defendants, state agency executives, from enforcing the Act's requirements. After a remand, the Fifth Circuit certified a question to the Supreme Court. The Supreme Court answered answered that Texas law does not grant the state agency executives named as defendants any authority to enforce the Act's requirements, either directly or indirectly. View "Whole Woman's Health v. Jackson" on Justia Law