The Indiana Supreme Court has reversed the denial of a woman’s claim against a hospital that discharged her grandson just before he murdered her husband, remanding for reconsideration of her motion to amend under IndianaTrial Rule 15(C).
In 2018, Betty Miller sued numerous health care providers for negligently treating her mentally ill grandson, Zachary Miller, after he arrived at Community Howard Regional Health Hospital’s emergency room and requested admission for his mental illness and dangerous propensities, but was treated and discharged.
Zachary, who had been treated at least five times over a month for serious mental health issues, upon discharge from Community Howard killed Betty’s husband, John Allen Miller.
After filing her suit, Miller moved in February 2020 to amend her complaint under Trial Rule 15(C) to add a new claim against Community Health Network Inc. and Community Howard Regional Health Inc., which owned and operated Community Howard Regional Health Hospital, for violating the Emergency Medical Treatment and Labor Act.
The Marion Superior Court denied her motion, relying heavily on Williams v. Inglis, 142 N.E.3d 467, 476 (Ind. Ct. App. 2020), which held EMTALA’s two-year statute of limitations preempted an amendment under Trial Rule 15(C). The Indiana Court of Appeals agreed and affirmed, but Judge Elizabeth Tavitas dissented, arguing that it would be “inconsistent to hold that Indiana Trial Rule 15(C) ‘directly conflicts with’ … EMTALA when federal courts have allowed relation back under the similar federal rule.”
Indiana justices reversed for Miller on Thursday, finding EMTALA’s statute of limitations does not expressly preempt Miller’s proposed amendment under Trial Rule 15(C).
“We fail to see how an amendment under Trial Rule 15(C) directly conflicts with EMTALA’s statute of limitations when an amendment under the equivalent federal rule would not,” Justice Mark Massa wrote. “Because there is no material difference between the two procedural rules, Miller is not trying to use state law to ‘extend, expand, or enlarge’ her federal rights. Both rules work harmoniously with statutes of limitations by bringing claims within the necessary time period. EMTALA’s express preemption clause does not prevent Miller’s proposed amendment because there is no direct conflict.”
Additionally, the justices concluded that there was no implied preemption that would prevent Miller’s proposed amendment under Trial Rule 15(C). Upon consideration of the two strands of implied preemption — conflict and field — the high court concluded neither prohibits Miller’s proposed amendment.
“Because we find EMTALA’s statute of limitations does not preempt an amendment under Trial Rule 15(C), we reverse the trial court,” it concluded. “In denying Miller’s motion, the trial court focused only on preemption. It must now consider whether the EMTALA claim arose out of the same conduct set forth or attempted to be set forth in the original complaint, along with other relevant factors.”
It therefore remanded for reconsideration of Miller’s motion in light of the justices’ opinion in Betty Miller, Individually and as Personal Representative of the Estate of John Allen Miller v. Laxeshkumar Patel, M.D., et al., 21S-CT-455.