Sunday, November 24, 2013

Woods v. Holy Cross Hospital case brief

Woods v. Holy Cross Hospital case brief summary
591 F.2d 1164 (5th Cir. 1979)


CASE SYNOPSIS
Appellant personal representative sought review of a judgment from the United States District Court for the Southern District of Florida dismissing appellant's claim of medical malpractice against appellees, a hospital and two physicians.

CASE FACTS
The court affirmed the decision of the district court. Appellant was a personal representative of the estate of a deceased who was treated by appellees, a hospital and two physicians. Appellant filed a medical malpractice claim against appellees, which the district court dismissed due to appellant's failure to comply with a state law requiring mediation of the claim.

DISCUSSION

  • On appeal, the court held that the mediation process required by state law was substantive rather than procedural law and therefore applied to federal cases. 
  • The court held that the inapplication of the law to noncitizens in diversity cases would be unfair to state citizens. 
  • The court held that the classification created by the law had a reasonable basis and that the mediation panel process was rationally related to a legitimate government interest, and therefore was not violative of equal protection rights or the Due Process Clause. 
  • The court further held that the state requirement did not infringe on appellant's U.S. Constitutional Amendment VII right to a trial by jury. 
  • The court held that appellant's other contentions lacked merit and therefore affirmed the dismissal.
CONCLUSION
The court affirmed the district court's judgment dismissing appellant personal representative's medical malpractice claim. The mediation process required by state law was substantive in nature and not violative of Equal Protection, Due Process, or Seventh Amendment rights.

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