Ex parte Addiction & Mental Health Services, Inc. (In re Anthony Stepter v. Bradford Health Services)

Summary

The Supreme Court of Alabama denied Bradford Health Services' petition for a writ of mandamus seeking transfer of a patient's action from Tuscaloosa County to Jefferson County under the Alabama Medical Liability Act. The court held that the Act's venue provision applies only to claims involving medical malpractice or medical injury, and that the patient's claims concerning disclosure of confidential treatment information did not involve medical injuries. Accordingly, the trial court properly denied the motion to transfer.

Holdings

1. The Alabama Medical Liability Act does not apply to every claim arising out of a relationship between a health-care provider and a patient; it applies only to medical-malpractice actions seeking redress for a medical injury in the context of a patient-doctor or patient-hospital relationship.
2. The Alabama Medical Liability Act's venue provision did not apply because Stepter's claims did not seek redress for medical injuries; therefore, the action was not required to be transferred to Jefferson County under that provision.
3. Bradford was not entitled to a writ of mandamus because it failed to demonstrate a clear legal right to transfer of the action.

Questions Presented

1. Whether Stepter's claims against Bradford were actions for medical injury governed by the Alabama Medical Liability Act.
2. Whether the Alabama Medical Liability Act's venue provision required transfer of the action from Tuscaloosa County to Jefferson County.
3. Whether Bradford had a clear legal right to mandamus relief from the trial court's denial of its motion to transfer.

Disposition

writ_denied