Justia Health Law Opinion Summaries

Alicia Sampson ("Alicia"), as administratrix of the estate of her deceased husband, Joshua Sampson ("Josh"), appealed the grant of summary judgment in favor of HeartWise Health Systems Corporation; HeartWise Clinic, LLC (collectively referred to as "HeartWise"); Isaac Health & Prevention Partners, LLC ("Isaac Health"); William Nixon, M.D.; and Jeffrey Saylor, M.D., in a wrongful-death action. At its HeartWise clinic, Isaac Health administered a battery of up to 31 physical tests that were intended "to assist in the detection of early evidence of vascular and cardiac abnormalities." In 2015, 29-year-old Josh visited the Isaac Health clinic. Months earlier, Josh's father died at age of 56 from "right ventricular dysplasia," which was a "congenital heart defect." Lowell's death led the Sampson family to seek heart evaluations to determine whether they had inherited the heart defect. Josh underwent the full battery of testing provided at the Isaac Health clinic; Josh's data from the left ventricular echocardiogram was within the "normal" range. Josh's mother, who also received the testing, stated that the nurse practitioner did not tell Josh in any way that he "needed to have any further diagnostic work-up or testing relative to his heart." On October 5, 2015, Josh collapsed at home while working on a construction project. He was taken to the Emergency Room, but died that day. The Sampson family procured a private autopsy; the report concluded that Josh died due to an arrhythmia secondary to hypertrophic cardiomyopathy, a congenital heart condition. Alicia thereafter filed suit against the clinic, HearWise and the doctors, alleging fraud and negligence. The Alabama Supreme Court reversed summary judgment entered in favor of Isaac Health and Drs. Nixon and Saylor with respect to Alicia's negligence allegations against them because those allegations were never properly presented to the circuit court for adjudication. The Court also reversed summary judgment in favor of HeartWise with respect to Alicia's fraud allegations against HeartWise because Alicia presented substantial evidence of Josh's reasonable reliance upon HeartWise's representations about its program. The Court affirmed summary judgment in favor of Isaac Health with respect to Alicia's fraud allegations against Isaac Health because Alicia failed to present substantial evidence that Josh's course of conduct would have changed if he had not seen HeartWise materials in the Isaac Health clinic's waiting room. The Court also affirmed summary judgment in favor of HeartWise with respect to Alicia's negligence allegations against HeartWise for multiple reasons. View "Sampson v. HeartWise Health Systems Corporation, et al." on Justia Law

This appeal stemmed from a medical-malpractice wrongful-death action filed by Patricia West ("Mrs. West"), the personal representative of the estate of her husband, John West, Jr. ("Mr. West"), against Springhill Hospitals, Inc., d/b/a Springhill Memorial Hospital ("SMH"). In 2014, then 59-year-old Mr. West accidentally sliced most of the tip of his left thumb off when he was using a table saw in his shop. He went to the emergency room, at which he had surgery to suture the wound from the saw cut. Mr. West was given two pain medications for postsurgical care: Dilaudid, the brand name for hydromorphone, and Percocet, the brand name for the opioid oxycodone. Mr. West was admitted to the hospital following surgery for observation. He was given the prescribed pain medications while in the hospital. The hospital admitted prescribed doses of Dilaudid were administered to Mr. West, but Percoset was not. Mr. West was found unresponsive after the doses of Dilaudid, and no drugs to counteract opioid overdoses were given. Mrs. West's lawsuit alleged negligence against the hospital for failing to assess monitor her husband while in the hospital. A jury returned a verdict against SMH and awarded $35 million in punitive damages. The trial court thereafter entered judgment on the jury's verdict finding SMH liable. After a hearing concerning a remittitur of the punitive-damages award, the trial court reduced the amount of the award to $10 million. After review, the Alabama Supreme Court affirmed both the judgment entered on the jury's verdict finding SMH liable and the trial court's order reducing the punitive-damages award. View "Springhill Hospitals, Inc. v. West" on Justia Law

The First Circuit affirmed the judgment of the district court determining that Anonymous Appellant (AA) should be civilly committed upon the expiation of his prison sentence, holding that AA was not entitled to relief on his allegations of error.Seventy-three-year-old AA had a history of incarceration spanning more than five decades. During his incarceration AA began to exhibit psychotic symptoms and was diagnosed with having schizoaffective disorder, bipolar type, and antisocial personality disorder. Based on the concerns of a risk-assessment panel the government filed a petition for the civil commitment of AA pursuant to 18 U.S.C. 4246. The district court granted the petition. The First Circuit affirmed, holding that there was no error in the proceedings below. View "United States v. Anonymous Appellant" on Justia Law

Adams, born in 1960, smoked about a pack a day starting at age 18 and worked in coal mines at times between 1979-1995, mostly underground using a “cutting machine” in the “dustiest” areas. Adams struggled to breathe after his retirement. Adams’s 1998 application under the Black Lung Benefits Act, 30 U.S.C. 901(b), was denied because he failed to prove that he had pneumoconiosis. In 2008, Adams sought benefits from Wilgar. His treating physician, Dr. Alam, identified the causes of his 2013 death as cardiopulmonary arrest, emphysema, coal worker’s pneumoconiosis, throat cancer, and aspiration pneumonia.A 2019 notice in the case stated “the Court may look to the preamble to the revised” regulations in weighing conflicting medical opinions. Wilgar unsuccessfully requested discovery concerning the preamble and the scientific studies that supported its conclusions. The ALJ awarded benefits, finding that Adams had “legal pneumoconiosis” and giving Dr. Alam’s opinion that Adam’s coal mine work had substantially aggravated his disease “controlling weight.” All things being equal, a treating physician’s opinion is “entitled to more weight,” 30 C.F.R. 718.104(d)(1). Wilgar's three experts had opined that Adams’s smoking exclusively caused his disease The ALJ gave “little weight” to these opinions, believing that they conflicted with the preamble to the 2001 regulation.The Benefits Review Board and Sixth Circuit affirmed. The preamble interpreted the then-existing scientific studies to establish that coal mine work can cause obstructive diseases, either alone or in combination with smoking. The ALJ simply found the preamble more persuasive than the experts. View "Wilgar Land Co. v. Director, Office of Workers’ Compensation Programs" on Justia Law

Plaintiffs are individual physicians based in Arizona, joined by several Arizona medical and advocacy groups. The named Defendants are Arizona Attorney General Kristin Mayes, all Arizona County Attorneys, and various state enforcement agencies. The Attorney General declined to defend this lawsuit, and the district court allowed Warren Petersen, President of the Arizona Senate, and Ben Toma, Speaker of the Arizona House of Representatives, to intervene. This suit by Arizona physicians, medical associations, and advocacy groups claims that an Arizona law criminalizing the performance of certain abortions is unconstitutionally vague. The district court denied a preliminary injunction, finding that Plaintiffs lacked standing.   The Ninth Circuit reversed and remanded. The panel held that the physician plaintiffs had demonstrated both actual and imminent injuries sufficient for standing. Plaintiffs suffered an actual injury—economic losses— because they lost money by complying with the laws, which forbade them from providing medical services they would otherwise provide, and these economic losses were fairly traceable to the statute. A favorable decision would relieve plaintiffs of compliance with the laws and restore the revenue generated by the prohibited procedures. Plaintiffs sufficiently alleged two imminent future injuries that affected interests protected by the Fifth and Fourteenth Amendments: (1) a liberty interest that was imperiled because violating the statute could result in imprisonment; and (2) a property interest that was threatened because a statutory violation could result in revocation of plaintiffs’ licenses, loss of revenue, and monetary damages. Finally, plaintiffs satisfied the causation and redressability requirements with respect to their imminent future injury. View "PAUL ISAACSON, ET AL V. KRISTIN MAYES, ET AL" on Justia Law

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

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

The Supreme Court affirmed the orders entered by the circuit court granting summary judgment to Defendants in the underlying action brought after investigators identified unsafe, non-sterile injection techniques, holding that the circuit court did not err.Plaintiffs, a pain management clinic and its physician, brought the underlying action alleging that the West Virginia Department of Health and Human Resources, West Virginia Bureau for Public Health, and its former Commissioner and State Health Officer (collectively, the DHHR Defendants) breached their duty of confidentiality when they issued a press release announcing that Defendants used unsafe injection practices and encouraging Plaintiffs' patients to be tested for bloodborne illnesses. Plaintiffs also sued the West Virginia Board of Ostseopathic Medicine and its executive director (together, the BOM Defendants), asserting a due process claim for failing to timely provide a hearing after their summary suspension of the physician's medical license. The circuit court concluded that the DHHR defendants were entitled to qualified immunity and that the claim against the BOM defendants was barred by res judicata. The Supreme Court affirmed, holding that there was no error in the circuit court's judgment. View "Chalifoux v. W. Va. Dep't of Health & Human Resources" on Justia Law

The Supreme Court affirmed the decision of the district court granting summary judgment in favor of the State in this action brought by Plaintiffs claiming that a contract health care provider for the State at the Wyoming Medium Correctional Institution (prison) acted negligently when she injected Appellants with the Janssen COVID-19 vaccine, holding that the State was immune from suit and liability.Plaintiffs, inmates at the prison, brought this action claiming that they were wrongfully injected with the Janssen COVID-19 vaccine because the consent forms Plaintiffs signed mentioned only the Moderna and Pfizer COVID-19 vaccines. The district court declined to allow Appellants additional time for limited discovery and granted summary judgment in favor of the State, finding that State had immunity. The Supreme Court affirmed, holding (1) the district court did not err when it declined to allow Plaintiffs limited discovery; and (2) the federal Public Readiness and Emergency Preparedness Act shielded the State from suit and liability in this case. View "Bird v. State" on Justia Law

A.I. appealed a district court’s order continuing her commitment to the North Dakota State Hospital (“NDSH”) for a period not to exceed 180 days. She argued the court erred in not ordering a less restrictive alternative treatment as testimony supported A.I.’s needs could be met with a lower level of care. In addition, A.I. asserted the entry of an order, that indicated a waiver of the continuing treatment hearing filed after a hearing was held, was clearly erroneous. The North Dakota Supreme Court concluded the court’s order to continue her hospitalization was not clearly erroneous, and the court’s order following waiver of treatment or continuing treatment hearing, as conceded by both parties, was entered in error. The Court affirmed the district court’s order for continued treatment and vacated the superfluous order entered in the record at docket entry 43. View "Interest of A.I." on Justia Law