In a ruling today the Idaho Supreme Court has reversed the district court’s dismissal of a medical malpractice case brought by Rockne Hollingsworth before a determination on the merits. In Idaho a government run hospital must receive notice of the claim within 180 days of an injury under the Idaho Tort Claims Act (“ITCA”). The district court ruled that even though the business filings with the Idaho Secretary of State made by the defendant Walter Knox Memorial Hospital created the false impression the hospital was a private corporation called Walter Knox Community Hospital, Inc. d/b/a Valor health, the case should be dismissed because of a lack of correct notice. The district court would not let the case proceed. The reversal of that ruling by the Idaho Supreme Court is the second successful outcome Hepworth Holzer LLP has obtained on behalf of a client at the Court this month.
Kurt Holzer argued the case on behalf of Mr. Hollingsworth who, instead of being transferred to a facility that could take care of him when he went to the emergency room with an obvious heart issue, was released by the doctor at the hospital. Within days of that improper release from care, Mr. Hollingsworth suffered massive heart damage that was preventable if he had received proper care. He was finally sent to the correct hospital. Mr. Hollingsworth brought suit for the life changing losses he should not have faced. In the litigation, he had been misled by the hospital’s corporate filings and treated the hospital like a private hospital. This led to the suit being filed after 180 day had elapsed. The hospital argued that was his tough luck because he was supposed to follow the ITCA 180-day requirement even though the hospital’s documentation filed with the state showed it was private. In its telling, the business corporation was the same as the county hospital and thus Mr. Hollingsworth was out of luck.
After reviewing the facts, the Idaho Supreme Court agreed with Hepworth Holzer that the case should be allowed to proceed. The Court concluded that the district court erred in holding Mr. Hollingsworth could not properly rely on the corporate filings of the hospital. Idaho law requires those filings be accurate and it was reasonable for Mr. Hollingsworth and his counsel to rely on those filings. Based on those those filings which showed Walter Knox Community Hospital, Inc., d/b/a Valor Health as the provider, it was a properly named defendant. They were corporate filings that misled plaintiff into acting as if the hospital was not a governmental entity subject to the ITCA. Additionally, the Idaho Supreme Court concluded the doctrine of quasi-estoppel applied which entitles the Hollingsworths to proceed against the county hospital.
Mr. Hollingsworth will now be allowed to pursue his claim for a determination on the merits. The case returns to the Third District Court for further proceedings.