Justia Health Law Opinion Summaries

The case involves the West Virginia Department of Health, Office of the Chief Medical Examiner, and Dr. Allen R. Mock (collectively "Petitioners") and Dr. Patsy Cipoletti, Jr., administrator of the estate of his deceased wife, June Cipoletti ("Respondent"). The Respondent filed a complaint against the Petitioners, alleging that they violated the West Virginia Medical Professional Liability Act (MPLA) by negligently determining Mrs. Cipoletti’s cause of death. The Petitioners filed a motion to dismiss, arguing that the Respondent had not asserted a proper cause of action under the MPLA. The circuit court denied the motion to dismiss, determining that the MPLA applied and that Petitioners were not entitled to qualified immunity.The Circuit Court of Kanawha County denied the Petitioners' motion to dismiss. The court determined that the MPLA applied and that Petitioners were not entitled to qualified immunity. The court found that Dr. Mock’s conduct fell under and was governed by the MPLA, thus depriving Petitioners of qualified immunity.The Supreme Court of Appeals of West Virginia reversed the circuit court's decision. The court found that the Petitioners' actions were discretionary and not in violation of any "clearly established statutory or constitutional rights or laws" and were not "otherwise fraudulent, malicious, or oppressive." Therefore, the court concluded that the Petitioners were entitled to qualified immunity from the lawsuit. The court also found that the Respondent had failed to plead a viable MPLA cause of action against the Petitioners. The court remanded the case to the circuit court with directions to grant the Petitioners' motion to dismiss. View "West Virginia Department of Health v. Cipoletti" on Justia Law

The case involves Novartis Pharmaceuticals Corporation and United Therapeutics Corporation, both drug manufacturers, and the Health Resources and Service Administration (HRSA). The dispute centers around Section 340B of the Public Health Service Act, which mandates drug manufacturers to sell certain drugs at discounted prices to select healthcare providers. These providers often contract with outside pharmacies for distribution. The manufacturers argued that these partnerships have left the Section 340B program vulnerable to abuse, leading them to impose their own contractual terms on providers, such as limits on the number of pharmacies to which they will make shipments. The government contended that these restrictions violate the statute.The case was initially heard in the United States District Court for the District of Columbia. The district court ruled that Section 340B does not prohibit manufacturers from limiting the distribution of discounted drugs by contract.The case was then reviewed by the United States Court of Appeals for the District of Columbia Circuit. The court agreed with the district court's ruling, stating that Section 340B does not categorically prohibit manufacturers from imposing conditions on the distribution of covered drugs to covered entities. The court further held that the conditions at issue in this case do not violate Section 340B on their face. The court did not rule out the possibility that other, more onerous conditions might violate the statute or that these conditions may violate Section 340B as applied in particular circumstances. The court affirmed the district court's decision to set aside the enforcement letters under review, while reserving the possibility of future enforcement under theories of liability narrower than the one pressed here. View "Novartis Pharmaceuticals Corporation v. Johnson" on Justia Law

The case involves the Roman Catholic Diocese of Albany and other entities, who provide medical insurance plans to their employees. They challenged a regulation by the Department of Financial Services, which requires New York employer health insurance policies that provide hospital, surgical, or medical expense coverage to include coverage for medically necessary abortion services. The plaintiffs argued that the exemption for "religious employers" was too narrow, violating the First Amendment rights of certain types of religiously affiliated employers who do not meet the terms of the exemption.The case began in 2016, raising a federal Free Exercise Claim that was similar to a previous case, Catholic Charities of Diocese of Albany v Serio. The lower courts dismissed the plaintiffs' complaints based on the principle of stare decisis, and the Appellate Division affirmed on the same ground. The plaintiffs appealed to the Supreme Court of the United States, which remanded the case to the Appellate Division to reconsider in light of a recent decision, Fulton v Philadelphia.On remand, the Appellate Division held that Serio was still good law and affirmed its previous decision that neither the medically necessary abortion regulation nor the "religious employer" exemption as defined violated the Free Exercise Clause. The Court of Appeals agreed, stating that under Fulton, both the regulation itself and the criteria delineating a "religious employer" for the purposes of the exemption are generally applicable and do not violate the Free Exercise Clause. The court concluded that the "religious employer" exemption survives the general applicability tests delineated in Fulton, and therefore, the Appellate Division order should be affirmed. View "Roman Catholic Diocese of Albany v Vullo" on Justia Law

Carlos Esteras and Raphael Frias were convicted of fentanyl trafficking charges and appealed their sentences, arguing that the district court erred in calculating their respective Guidelines ranges. Esteras contended that the district court wrongly calculated his base offense level by applying a two-level increase for maintaining a premises for narcotics trafficking and declining to apply a two-level reduction for being a minor participant in the trafficking scheme. He also argued that the district court wrongly applied a two-point increase to his criminal history score after finding that he was on parole at the time of the offense. Frias argued that the district court erred in applying the two-level premises enhancement and a four-level increase for being an organizer or leader of the scheme, and failed to adequately consider his mitigating evidence in declining to vary downwards.The United States District Court for the Northern District of New York had sentenced Esteras to 84 months' imprisonment and Frias to 135 months' imprisonment. The court had applied several sentencing enhancements, including a two-level enhancement for maintaining a premises for narcotics trafficking and a four-level enhancement for being an organizer or leader of the scheme.The United States Court of Appeals for the Second Circuit affirmed each of the district court’s sentencing decisions except its application of the organizer or leader enhancement to Frias. The court affirmed Esteras’s sentence and vacated and remanded Frias’s sentence for further proceedings consistent with its opinion. The court found that Esteras's home qualified for the stash-house enhancement and that he was not a minor participant in the conspiracy. The court also found that Esteras was on parole when he committed his offenses, warranting a two-point increase to his criminal history score. However, the court found that Frias did not qualify as an organizer or leader under the Guidelines, warranting a remand for further proceedings. View "United States v. Frias" on Justia Law

The case revolves around an employment discrimination suit filed by Dr. Tara Loux against her former employers, BayCare Medical Group and St. Joseph’s Hospital. Dr. Loux sought to discover BayCare’s internal documents about the performance of other doctors who were not fired despite also committing errors. BayCare objected to disclosing certain documents, such as its “quality files” and “referral logs,” arguing that they were privileged under the Patient Safety and Quality Improvement Act of 2005. The Act creates a statutory privilege for work product prepared for or reported to patient safety organizations.The district court ordered BayCare to produce the disputed documents, concluding that the Act does not privilege documents if they have a “dual purpose,” only one of which relates to making reports to a patient safety organization. The court held that these documents were not privileged because BayCare used information in the documents for other purposes, such as internal safety analysis and peer review.The United States Court of Appeals for the Eleventh Circuit disagreed with the district court's interpretation of the Act. The appellate court found that the district court had applied an incorrect "sole purpose" standard to assess whether BayCare’s quality files and referral logs fell under the privilege. The court held that the Act does not require that privileged information be kept solely for provision to a Patient Safety Organization. The court granted BayCare's petition for a writ of mandamus, directing the district court to vacate its orders compelling the disclosure of the privileged documents and reconsider BayCare’s assertion of privilege consistent with the appellate court's opinion. View "In re: Baycare Medical Group, Inc." on Justia Law

The case involves D.K., a patient diagnosed with an unspecified schizophrenia spectrum and other psychotic disorders, who was found incompetent to stand trial and committed to the Department of State Hospitals (DSH) by the Orange County Superior Court. After D.K.'s transfer to Napa State Hospital, DSH filed a petition for an interim order to compel involuntary medication of D.K. with antipsychotic medication. An administrative law judge (ALJ) conducted an evidentiary hearing and ordered D.K. involuntarily medicated from January 17, 2023, to February 7, 2023. D.K. filed a petition for a writ of administrative mandate with the Napa County Superior Court, challenging the medication order. The superior court denied her petition, concluding D.K. was not entitled to writ review.The Court of Appeal of the State of California First Appellate District Division Three found that D.K.'s appeal was moot because the order had expired and no meaningful relief could be effectuated through review of that order. However, the court exercised its discretion to address D.K.'s appeal of the superior court's finding that the statutory scheme of section 1370 precluded her from filing a writ of administrative mandamus to challenge the medication order. The court concluded that both the significant liberty interests at issue and the language of section 1370 support D.K.'s right to seek writ review. The court reversed the superior court's holding that D.K. was not entitled to writ review. However, it dismissed as moot D.K.'s challenge to the court's finding that substantial evidence supported the involuntary medication order, so it did not remand the case for further proceedings. View "D.K. v. Office of Admin. Hearings" on Justia Law

The case involves a patent infringement dispute between Copan Italia S.p.A. and Copan Diagnostics Inc. (collectively, “Copan”) and Puritan Medical Products Company LLC and its affiliated companies (collectively, “Puritan”). Copan, the holder of several patents on flocked swabs used for collecting biological specimens, filed a patent infringement complaint against Puritan in the District of Maine. Puritan, in response, filed a partial motion to dismiss, claiming immunity under the Pandemic Readiness and Emergency Preparedness Act (“PREP Act”) for a portion of its accused product.The District Court for the District of Maine denied Puritan's motion to dismiss. The court found that Puritan had not shown, as a factual matter, that its flocked swabs were “covered countermeasures” under the PREP Act. The court also granted Puritan’s motion to amend its answer, allowing it to assert PREP Act immunity as a defense, subject to further argument.Puritan appealed the decision to the United States Court of Appeals for the Federal Circuit. However, the appellate court found that it lacked jurisdiction to review the case. The court reasoned that the district court's denial of Puritan's motion to dismiss did not conclusively determine any issue, which is a requirement for the application of the collateral order doctrine. The court suggested that the district court may wish to structure the litigation in a manner that could allow it to make a conclusive determination on Puritan’s PREP Act immunity defense before the case proceeds any further. The appeal was dismissed due to lack of jurisdiction. View "COPAN ITALIA SPA v. PURITAN MEDICAL PRODUCTS COMPANY LLC " on Justia Law

The case revolves around John Doyle, who was charged with crimes stemming from a domestic dispute. In August 2019, the trial court ordered Doyle to undergo a competency evaluation, and his mental health and medical records were provided to the Office of the Forensic Examiner (OFE). The court specified that these records could only be used to determine competency and not for any other proceeding without a court order. The OFE concluded that Doyle was not competent to stand trial but could be restored to competence with appropriate treatment. However, an independent examiner concluded that Doyle was unlikely to be restored to competency. In August 2021, the OFE re-evaluated Doyle and concluded that he had not been restored to competency and was dangerous to himself or others.The trial court had previously ruled that Doyle's medical and mental health records were exempt from the physician-patient and psychotherapist-patient privileges, allowing the State to release these records to a physician designated by the State for assessing the appropriateness of involuntary commitment. Doyle appealed this decision, arguing that the court erred in ruling that his records were exempt from these privileges.The Supreme Court of New Hampshire vacated the trial court's decision and remanded the case. The Supreme Court found that the trial court erred in determining that Doyle's medical and mental health records were exempt from statutory privileges under RSA 135:17-a, V. The court concluded that these records were privileged under RSA 329:26 and RSA 330-A:32, and the trial court erred in determining that they were exempt from these privileges. The case was remanded for further proceedings to determine whether there were grounds for disclosing the privileged information. View "State v. Doyle" on Justia Law

The case revolves around Anna Lange, a transgender woman employed by the Houston County Sheriff's Office in Georgia. Lange was diagnosed with gender dysphoria in 2017 and her healthcare providers recommended a treatment plan that included hormone therapy and gender-affirming surgery. In 2018, her healthcare providers determined that a vaginoplasty was medically necessary. However, Lange's request for coverage was denied based on the health insurance plan's exclusion of services and supplies for sex change and/or the reversal of a sex change. Lange filed claims against Houston County with the Equal Employment Opportunity Commission and subsequently sued Houston County and the Sheriff of Houston County in the Middle District of Georgia.The district court granted summary judgment to Lange on the Title VII claim, finding the Exclusion facially discriminatory as a matter of law. The Title VII claim then proceeded to trial, and a jury awarded Lange $60,000 in damages. After trial, the district court entered an order declaring that the Exclusion violated Title VII and permanently enjoined the Sheriff and Houston County from any further enforcement or application of the Exclusion.The United States Court of Appeals for the Eleventh Circuit affirmed the district court's decision. The court held that a health insurance provider can be held liable under Title VII of the Civil Rights Act of 1964 for denying coverage for gender-affirming care to a transgender employee because the employee is transgender. The court also held that Houston County is liable under Title VII as an agent of the Sheriff's Office. The court affirmed the district court's order permanently enjoining Houston County and the Sheriff from further enforcement or application of the Exclusion. View "Lange v. Houston County, Georgia" on Justia Law

The case involves a wrongful death claim filed by Judith Rygwall, the mother of Amy Rygwall, against ACR Homes, Inc. Amy, a profoundly vulnerable woman with intellectual and physical disabilities, was under the care of ACR Homes. On New Year's Eve 2015, Amy aspirated (inhaled food into her lungs) and began showing signs of respiratory distress. A member of ACR's staff was informed of these signs but did not seek immediate emergency care for Amy. Instead, she searched online for an urgent care clinic that accepted Amy's insurance with the shortest wait time. Amy's condition worsened, and she died 13 days later from related complications. Rygwall filed a wrongful-death action, asserting that ACR should have immediately called 911 upon learning of Amy's respiratory distress and that failure to do so caused Amy's death.ACR moved for summary judgment on the issue of causation. The district court granted ACR's motion, and the court of appeals affirmed. The district court concluded that Rygwall did not establish that Amy would not have died even if she had received emergency care soon after she exhibited respiratory distress and aspirated after lunch at Rise. The court of appeals agreed, reasoning that Rygwall's expert's report did not explain how Amy's treatment would have progressed had she been seen sooner or how immediate treatment would have prevented her condition from becoming fatal.The Supreme Court of Minnesota reversed the decision of the court of appeals and remanded the case to the district court for further proceedings. The Supreme Court held that Rygwall raised a genuine issue of material fact as to whether ACR caused her daughter's death. The court concluded that based on the record, a reasonable jury could find in Rygwall's favor on the issue of causation, and therefore summary judgment for ACR was inappropriate. View "Rygwall vs. ACR Homes, Inc." on Justia Law