Justia Health Law Opinion SummariesArticles Posted in Wyoming Supreme Court
Wiese v. Riverton Memorial Hospital, LLC
The Supreme Court reversed the order of district court granting summary judgment to Riverton Memorial Hospital, LLC and dismissing this complaint alleging that Hospital violated the now-repealed Wyoming Hospital Records and Information Act, Wyo. Stat. Ann. 35-2-605 to 35-2-617, holding that a genuine issue of material fact existed precluding summary judgment.In their complaint, Rebecca and Tyler Wiese claimed that the Hospital failed to provide them all "health care information" concerning Rebecca's labor and delivery, including information associated with her Centricity Perinatal electronic medical record, in violation of the Act. The district court granted summary judgment of the Hospital, concluding that the Hospital complied with the Act by informing the Wieses and that Centricity electronic record and audit trial did not exist and/or could not be found. The Supreme Court reversed, holding (1) audit trails were "health care information" under the Act; and (2) a genuine issue of material fact existed as to whether Hospital complied with the Act with respect to Rebecca's Centricity electronic record and audit trail. View "Wiese v. Riverton Memorial Hospital, LLC" on Justia Law
Peterson v. Meritain Health, Inc.
The Supreme Court reversed in part and affirmed in part the decision of the district court granting summary judgment for Meritain Health, Inc., and dismissing David Peterson's claims against Meritain, holding that there were genuine issues of material fact as to some of Peterson's claims.Peterson, an insured under a hospital's health benefit plan, brought this action against the hospital and Meritain Health, Inc., the third-party administrator of the plan, alleging several claims arising from the denial of his claims for health insurance coverage. The district court granted Meritain's motion for summary judgment. The Supreme Court reversed in part and remanded the case, holding that there were genuine issues of material fact regarding Peteron's breach of contract claim, his third-party beneficiary claim, and his claim for breach of the covenant of good faith and fair dealing. View "Peterson v. Meritain Health, Inc." on Justia Law
Wyoming State Hospital v. Romine
The Supreme Court affirmed in part and dismissed part the judgment of the district court denying summary judgment in favor of the Wyoming State Hospital on Plaintiffs' claims asserting various claims of negligence under the Wyoming governmental Claims Act, Wyo. Stat. Ann. 1-39-101 - 120, holding that section 1-30-110's waiver of governmental immunity is not limited to medical malpractice claims.In denying the Hospital's motion for summary judgment, the district court concluded (1) the Hospital had waived its immunity under section 1-39-110, and (2) genuine issues of material fact precluded summary judgment. The Supreme Court affirmed in part and dismissed in part, holding (1) because it did not involve the purely legal issue of whether the Hospital was immune from suit under the Claims Act, the Hospital's appeal with respect to section 1-39-118 and proximate cause is dismissed for lack of jurisdiction; and (2) the district court did not err in concluding that the Hospital had waived its immunity under section 1-39-110. View "Wyoming State Hospital v. Romine" on Justia Law
Miller v. Life Care Centers of America, Inc.
The Supreme Court reversed the judgment of the district court granting Defendant's motion to compel arbitration under the "voluntary agreement for arbitration" Rick Miller signed on behalf of his mother, Julia Miller, after she was admitted to Life Care Center of Casper (LCCC), holding that Rick lacked authority to execute the agreement.After Julia died allegedly from injuries sustained during a series of mishaps at LCCC Rick filed this complaint stating claims of negligence and premises liability against Defendant. Defendant filed a motion to compel arbitration. The court granted the motion. The Supreme Court reversed, holding (1) Julia's durable power of attorney for health care did not grant Rick express actual authority to sign the arbitration agreement; (2) Julia did not hold Rick out as having apparent authority to sign the agreement; and (3) Rick was not authorized to execute the arbitration agreement as Julia's "surrogate" under the Wyoming Health Care Decisions Act, Wyo. Stat. Ann. 35-22-401 through 416. View "Miller v. Life Care Centers of America, Inc." on Justia Law
MH v. First Judicial District Court of Laramie County
The Supreme Court reversed the judgment of the district court denying for lack of subject matter jurisdiction Petitioner's petition for an order recognizing her change of sex and gender so that she could amend her birth certificate, holding that the district court had subject matter jurisdiction.Petitioner's birth certificate identified her as male, but Petitioner identified and held herself out as female. Petitioner petitioned the district court for an order recognizing her change of sex and gender pursuant to its power of general jurisdiction and Wyo. Stat. Ann. 35-1-424(a). The district court denied the petition, concluding that neither the Wyoming Constitution, Wyo. Stat. Ann. 35-1-424, nor the rules of the Wyoming Department of Health (WDOH) granted it subject matter jurisdiction. The Supreme Court reversed, holding (1) the Wyoming Constitution and precedent require a presumption in favor of district court subject matter jurisdiction; (2) the Vital Records Act provides the district court subject matter jurisdiction to address Petitioner's petition for sex change; and (3) therefore, the district court has subject matter jurisdiction. View "MH v. First Judicial District Court of Laramie County" on Justia Law
Life Care Center of Casper v. Barrett
The Supreme Court vacated the order of the district court holding Life Care Center of Casper in contempt when it failed to comply with an order compelling it to respond to a subpoena served on it in an action for appointment of a wrongful death representative, holding that the district court lacked jurisdiction to compel pre-suit discovery in the appointment proceeding.Plaintiff, the granddaughter of Betty June Cochran, filed a petition to be appointed Cochran's wrongful death representative after Cochran died allegedly after a fall at Life Care Center of Casper. The district court granted the petition. Thereafter, Plaintiff served life Care with a subpoena to compel discovery. Life Care provided only some of the subpoenaed documents. Plaintiff filed a motion to compel, and the district court granted the motion in part. Life Care filed a Wyo. R. Crim. P. 60(b)(6) motion requesting that the district court vacate its order compelling discovery. The district court denied the motion and found Life Care to be in civil contempt. The Supreme Court vacated the order, holding that the district court did not have jurisdiction under Wyo. Stat. Ann. 1-38-103 to compel pre-suit discovery because the sole purpose of a proceeding under section 1-38-103(b) is the appointment of a wrongful death representative. View "Life Care Center of Casper v. Barrett" on Justia Law
Anderson v. State ex rel. Department of Health
The Supreme Court reversed the judgment of the district court upholding the decision of the Department of Health for Medicaid, holding that the Department did not act in accordance with law when it denied Lucile Anderson’s application to have her sons’ payment of her attorney fees treated as a return of assets.The Department found Anderson eligible for nursing home benefits but suspended her eligibility as a penalty for her transfer of assets at below fair market value. Anderson’s sons paid the attorney fees and costs Anderson incurred in her unsuccessful appeal, and Anderson applied to have that payment treated as a return of assets, which would shorten the penalty period. The Department denied the application. The district court affirmed the Department’s decision. The Supreme Court reversed, holding that the Department erred in denying Anderson’s application because the Department’s Medicaid rules did not, as a matter of law, preclude the payment of Anderson’s attorney fees from being treated as a return of assets. View "Anderson v. State ex rel. Department of Health" on Justia Law
Wyoming Guardianship Corp. v. Wyoming State Hospital
The Supreme Court affirmed in part and reversed in part the district court’s dismissal of Plaintiff’s complaint alleging negligence and violations of 42 U.S.C. 1983 after Linda Gelok was injured after being left unattended for twenty-five hours at the Wyoming State Hospital (WSH), holding that the complaint alleged sufficient facts to state a claim for relief under 42 U.S. C. 1983 against Paul Mullenax, WSH Administrator, in his individual capacity.On behalf of Linda Gelok, an involuntarily committed incompetent person, Plaintiff sued the WSH, the Wyoming Department of Health, and Mullenax, WSH Administrator, in his official and individual capacities, alleging negligence and violation of her constitutional rights under 42 U.S.C. 1983. The district court dismissed the negligence action as time-barred. As to the constitutional claims, the district court found that the WSH, the Department, and Mullenax in his official capacity were entitled to Eleventh Amendment immunity and that Mullenax was entitled to qualified immunity in his individual capacity. The Supreme Court held (1) Wyo. Stat. Ann. 1-3-107 barred Plaintiff’s negligent health care claim; (2) the district court properly dismissed Plaintiff’s 42 U.S.C. 1983 claims against most defendants; but (3) Plaintiff’s complaint alleged sufficient facts to state a claim for relief under 42 U.S.C. 1983 against Mullenax in his individual capacity. View "Wyoming Guardianship Corp. v. Wyoming State Hospital" on Justia Law
Sands v. Brown
In 2010, the director of the Wyoming Guardianship Corporation filed a petition for emergency appointment of a temporary guardian for Robert Sands, who was then seventy years old and suffered from dementia and other medical problems. The district court held a guardianship was necessary and appointed Richard Brown as guardian. Sands sought to terminate the guardianship, and the district court denied the petition. Six months later, however, the district court held a review hearing and terminated the guardianship, finding there was no longer a need for the guardianship. Prior to the hearing, Sands filed a complaint against Brown, alleging that Brown had breached his duties. The district court ruled in favor of Brown on Sands' complaint, concluding that Brown substantially complied with the statutes and did not violate his fiduciary duties, and awarded Brown and his attorney fees and costs. The Supreme Court affirmed, holding that the district court did not err in when it denied Sands' petition to terminate the guardianship, reopened the guardianship for the purpose of awarding fees and costs, and dismissed Sands' complaint against Brown. View "Sands v. Brown" on Justia Law
State v. Wyo. State Hosp.
After RB, a middle-aged man, was emergently detained as a suicide risk at West Park Hospital, the district court involuntarily hospitalized RB at the Wyoming State Hospital, where he was detoxified of opiates and other controlled substances and eventually stabilized on psychotropic medications. The State Hospital then notified the district court and the county attorney that it intended to discharge RB. The county attorney filed an objection with the district court, claiming a right to a hearing on the merits of the State Hospital's decision. The district court concluded that the county had no standing to object to RB's discharge. The Supreme Court affirmed, holding that the involuntary hospitalization statutes do not provide authority for a county attorney to object to the proposed discharge of a patient from involuntary civil commitment. View "State v. Wyo. State Hosp." on Justia Law