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Court Discusses Procedural Requirements in Medical Malpractice Claims Involving Federal Entities

Medical professionals must exercise due diligence in monitoring and treating patients with mental health conditions, regardless of the treatment settings, and if they fail to do so, it may constitute medical malpractice. The legal consequences of inadequate healthcare services in correctional settings were demonstrated in a recent case involving the tragic suicide of a detainee at a federal facility. If you or a loved one suffered harm because of inadequate medical care, it is advisable to speak to a Baltimore medical malpractice attorney regarding your rights.

Factual Background and Procedural History

It is reported that the plaintiff, acting on behalf of herself and as the representative of a deceased detainee’s estate, brought a wrongful death and medical malpractice action against the defendants. In it, she alleged that while under the care of the jail and its healthcare providers, the decedent committed suicide. The plaintiff claimed that the defendants failed to adequately monitor, treat, and provide mental health accommodations for the decedent despite known risk factors and a documented history of psychiatric concerns.

It is further reported that the United States substituted itself for the defendants under the Federally Supported Health Centers Assistance Act, which treats certain nonprofit healthcare providers as employees of the federal government when acting within the scope of a qualifying grant-supported activity. Consequently, the plaintiff’s claims against the defendants were converted into claims under the Federal Tort Claims Act (FTCA), and those claims were later voluntarily dismissed.

The District, however, remained a defendant in the litigation and initiated a third-party action seeking indemnity from the defendants, relying on contractual provisions obligating the defendants to hold the District harmless for liabilities arising from medical services rendered under the contract. Unity responded with a motion to dismiss, arguing that the court lacked subject-matter jurisdiction over the indemnity claim and that because the United States had already substituted itself in the defendant’s place, it was immune from further litigation.

Jurisdictional Barriers and the Role of Federal Immunity

The court granted the defendant’s motion to dismiss the District’s indemnity claim, holding that the claim was jurisdictionally barred. Specifically, the court found that the defendant had been deemed a federal employee for purposes of the Public Health Service Act, which triggered immunity under the FTCA. This designation meant that the United States was the sole proper defendant for any claims arising out of the defendant’s provision of medical care.

Under the FTCA, plaintiffs are required to exhaust administrative remedies before filing suit, and lawsuits must be brought directly against the United States. The court ruled that since the defendant could not be held liable in its own name for conduct undertaken within the scope of its federally covered activities, the District could not maintain a separate indemnity action against the defendant. The court also noted that the contractual indemnity provisions were effectively unenforceable in light of federal preemption.

Furthermore, the court emphasized that extending liability to Unity would contravene congressional intent in enacting the Public Health Service Act and the FTCA, both of which are designed to streamline the handling of medical malpractice claims involving federally funded healthcare providers. Because the defendant’s alleged negligence occurred within the scope of its duties under the federal designation, the court dismissed the District’s third-party claim for indemnification.

Consult a Baltimore Medical Malpractice Attorney About Your Potential Claims

When inadequate care leads to harm or death, questions of liability and immunity can complicate litigation. If you or a loved one has suffered due to negligent medical treatment in an institutional setting, the knowledgeable Baltimore medical malpractice attorneys at Arfaa Law Group can help you assess your legal options. Contact our office at (410) 889-1850 or complete our online form to arrange a consultation and learn more about how we can help you pursue justice.

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