Summary
The Supreme Court of Tennessee held that the State qualifies as a governmental entity under Tennessee Code Annotated section 20-1-119(g), making Conley's claim timely when filed within 90 days of a defendant's allegation of the State's fault. The court nonetheless held that the complaint failed to state claims for medical malpractice and negligent care, custody, or control because no professional/client relationship with a state employee or State care, custody, or control was alleged. The court affirmed in part and reversed in part the Court of Appeals' judgment.
Topics
Practice areas
Questions Presented
- Whether Tennessee is a governmental entity for purposes of Tennessee Code Annotated section 20-1-119(g), so that the statute's ninety-day extension applies to a claim against the State.
- Whether a claim for medical malpractice against the State under Tennessee Code Annotated section 9-8-307(a)(1)(D) requires a professional/client relationship between the claimant and a state employee.
- Whether the State may be liable under Tennessee Code Annotated section 9-8-307(a)(1)(E) for negligent care, custody, or control based solely on its federally required pre-admission screening of a nursing-home patient.
Holdings
- The State of Tennessee is a governmental entity for purposes of section 20-1-119(g), and Conley's claim filed within ninety days of Lifecare's answer alleging the State's fault was timely.
- A medical-malpractice action against the State under Tennessee Code Annotated section 9-8-307(a)(1)(D) requires a professional/client relationship between the claimant and a state employee. Conley's complaint failed to state such a claim.
- The complaint did not state a claim under section 9-8-307(a)(1)(E) because the State did not have care, custody, or control of Johnson based on its limited role in administering pre-admission screening before his placement in a privately operated nursing facility.
Key quotations
“In view of this legislative history, we hold that the intent and purpose of the legislature was undoubtedly to include the State of Tennessee as a governmental entity for the purpose of Tennessee Code Annotated section 20-1-119(g) (Supp.2003).” (596)
“Accordingly, we hold that a medical malpractice action under Tennessee Code Annotated section 9-8-307(a)(1)(D) unambiguously requires a "professional/client" relationship between the claimant and a state employee.” (598)
Factual background
Martha Stinson was a patient at Centerville Health Care Center, a nursing home operated by Lifecare. On January 1, 2000, she was severely beaten by James Johnson, another resident who had been diagnosed with agitated psychosis, and later died from her injuries. After Lifecare alleged that the State was at fault for Johnson's pre-admission screening and placement, Patricia Conley filed a claim against the State alleging negligent screening.
Procedural history
Conley filed a wrongful-death action against Lifecare Centers of America after Martha Stinson died from injuries inflicted by another nursing-home patient. Lifecare later alleged that the State was comparatively at fault for negligently screening and placing the other patient, and Conley filed a separate claim against the State within ninety days of that answer. The Claims Commission dismissed the claim as untimely and for failure to state a claim. The Court of Appeals reversed and remanded. The Tennessee Supreme Court affirmed the timeliness ruling but reversed the rulings allowing the medical-malpractice and negligent-care claims to proceed.
Remand instructions
The Court of Appeals' judgment was affirmed in part and reversed in part. The supplied opinion does not state additional remand instructions beyond the prior remand for further proceedings being rejected as to the medical-malpractice and negligent-care claims.