New Jersey Appellate Court Reinstates Medical Malpractice Case Dismissed On Jurisdictional Grounds

Court Reinstates Medical Malpractice Case Dismissed On Jurisdictional Grounds: New Jersey medical malpractice plaintiffs Lou Anne Hiles and her husband Rodney Hiles are residents of Pilesgrove, New Jersey. On August 14, 2019, Lou Anne appeared at the emergency department of defendant Crozer Chester Medical Center (Crozer) in Upland, Pennsylvania. Lou Anne complained of numbness in her arms and legs that had worsened over a period of weeks. Crozer medical staff examined Lou Anne and admitted her to the center, where she
remained for three days. She was then transferred to a different hospital. The staff at the second hospital found that Lou Anne had a “foul smelling” decubitus ulcer of the sacral region, and diagnosed her with acute encephalopathy and
acute renal failure.

On August 11, 2021, Lou Anne filed a medical malpractice complaint against defendants, which included Crozer, a number of doctors and nurses, and Prospect Medical Holdings, L.L.C. (Prospect), which she alleged “owned, operated, maintained, and controlled” Crozer. Lou Anne alleged she suffered permanent debilitating and disabling injuries as the result of defendants’ misdiagnosis and failure to properly treat those ailments. Rodney asserted a derivative per quod claim as Lou Anne’s spouse and sought compensation for loss of consortium.

Plaintiffs filed their complaint in Essex County, New Jersey. Plaintiffs alleged that Prospect, Crozer’s parent company, owned and operated a hospital in that county. Defendants filed a motion to dismiss and alleged that the court lacked jurisdiction over plaintiffs’ claims, alleging that Crozer is a Pennsylvania-based limited liability company that does not do business in New Jersey. They also claimed that Crozer holds no property in New Jersey and does not solicit business from New Jersey. Defendants argued that even if Prospect operated a hospital in Essex County, its “parent-subsidiary relationship” with Crozer was not sufficient to establish general jurisdiction. Finally, defendants asserted New Jersey had no specific jurisdiction over them because all of Lou Anne’s care was rendered in Pennsylvania by healthcare provides that were practicing in that state. Defendants also claimed that Lou Anne entered Crozer by mere chance because she was in that area when she needed emergency medical care.

The trial court granted the defendants’ motion to dismiss, and the plaintiffs appealed.

The Superior Court of New Jersey Appellate Division stated in its per curiam opinion dated February 10, 2023: “we are convinced that the record was not sufficiently developed for the trial court to conclude, as it did, that defendants were not subject to New Jersey’s general or specific jurisdiction. The court seems to have accepted defendants’ blanket denial that Crozer had no relationship whatsoever with New Jersey and had never solicited business from this state.

However, plaintiffs argued otherwise and stated that Lou Anne’s decision to go to Crozer was the result of its enticements. She alleged she needed the opportunity for discovery from defendants to demonstrate this point. Plaintiffs also wanted to explore what connections, if any, the individual doctors and nurses had to New Jersey. As the trial court acknowledged, at least one of the doctors seemed to have sufficient contacts with New Jersey to support a claim of jurisdiction. However, the court denied plaintiffs the opportunity to seek information concerning the other defendants.

Plaintiffs were also not privy to the nature of the corporate relationship between Crozer, Prospect, and any facilities Prospect operated in New Jersey. It could not obtain that information without a limited period of jurisdictional
discovery.

Under these circumstances, we are satisfied that the matter was not ripe for determination at the time defendants filed their motion to dismiss. Rather, the trial court should have granted plaintiffs’ request for jurisdictional discovery
to explore defendants’ activities in, and connections to, New Jersey. Although such discovery may ultimately result in a determination that New Jersey does not have jurisdiction over some or all of the defendants, plaintiffs should not
have been prevented from attempting to establish a sufficient basis to proceed at this early juncture of the proceedings.”

Source Hiles v. Prospect Medical Holdings, Inc., Docket No. A-0556-22.

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