How a 3rd-Party Doctor Can Be Held in Med Mal Cases in NJ
The Supreme Court's ruling comes in a lawsuit against Quest Diagnostics and a doctor for allegedly failing to detect cervical cancer.
March 18, 2020 at 04:51 PM
3 minute read
The state Supreme Court has ruled that a third-party defendant in a medical malpractice suit facing contribution and common-law indemnification claims made by a defendant—even one lacking an affidavit of merit—must participate in the underlying liability trial.
The court's unanimous ruling Monday stems from plaintiff Samuel Mejia's lawsuit against Quest Diagnostics and Dr. Simon Santos for allegedly failing to detect his late wife Tania's cervical cancer. Quest, in turn, filed a third-party complaint against Tania's doctor, Dr. Jacinto Fernandez.
Fernandez argued that since he was not sued by the plaintiff, and because an affidavit of merit was never served on him by any party, he should not have been included in the litigation, according to Supreme Court Justice Faustino Fernandez-Vina's opinion.
The doctor pointed to Burt v. West Jersey Health Systems, in which defendants in a similar case were dismissed for failure to timely serve an affidavit.
However, Fernandez-Vina, noting that the trial court denied Fernandez's request, distinguished the cases because the defendants in Burt were "dismissed meritoriously."
"We agree and affirm" the trial court and Appellate Division, Fernandez-Vina said. "Third-party defendants are subject to the contribution claims filed against them by joint tortfeasors, unless there exists a right to a dismissal of the claims against them.
"Here, Fernandez fails to present a meritorious right to dismissal. Fernandez is therefore an active third-party defendant who must participate at trial," the justice wrote.
Fernandez-Vina said it was undisputed that Quest properly filed a third-party complaint.
"Pursuant to that claim for contribution, Fernandez is an active party in the litigation as a joint tortfeasor, regardless of plaintiff's decision not to file an affirmative claim against Fernandez. Therefore, a trial is necessary for the trier of fact to determine the allocation of percentage of negligence to each defendant," Fernandez-Vina said.
"While plaintiff cannot recover from Fernandez directly," he continued, "we agree with the Appellate Division that if the trier of fact determines defendants Quest or Santos to be sixty percent or more at fault, then plaintiff can recover the full amount of damages from that party, and if Fernandez is found to be between one and forty percent at fault, then he would be liable for his percentage of fault in contribution to the party that paid the full amount of damages to plaintiff."
Brian Mahoney of Blume, Forte, Fried, Zerres & Molinari represents Mejia and did not respond to a request for comment.
William Brennan of The Law Office of William L. Brennan represents Fernandez and also did not respond to a request for comment.
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllAmid Growing Litigation Volume, Don't Expect UnitedHealthcare to Change Its Stripes After CEO's Killing
6 minute readSpoliation of Evidence Costs Defendants Nearly $850K in Sanction Award
4 minute readFatal Shooting of CEO Sets Off Scramble to Reassess Executive Security
5 minute read$10 Million Settlement Reached for Baby Injured by Disconnected Ventilator
3 minute readTrending Stories
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250