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Knoxville Appeals Court Overturns Summary Judgment in Premises Liability Action Filed Against Hospital

In Coggins v. Holston Valley Medical Center, a woman and her spouse visited a patient in a Tennessee hospital. While at the medical facility, the woman apparently tripped over a feeding tube that was purportedly placed near the patient’s bed in a negligent fashion. As a result, the woman fell and sustained serious injuries. Later, the injured woman served the hospital with notice that she intended to file a lawsuit against the facility before ultimately filing her complaint.

In response to the woman’s case, the hospital filed a motion for summary judgment. In general, such a motion asks a court to rule that there are no material facts in dispute, and one party to a lawsuit is entitled to judgment as a matter of law. After reviewing the hospital’s motion, the trial court ruled that the woman’s claim constituted a premises liability action instead of a health care liability case. The trial court also found that the woman was not entitled to utilize the pre-suit notice provisions enumerated in Section 29-26-121 of the Tennessee Code to extend the statute of limitations. As a result, the lower court found that the woman’s case was not filed within the applicable one-year statute of limitations. After ruling the lawsuit was time-barred, the trial court granted the hospital’s motion for summary judgment.

On appeal, the Court of Appeals of Tennessee at Knoxville first stated no material facts were in dispute. Instead, the issues presented to the appellate court were questions of law. Next, the court agreed that the injured woman’s case constituted a premises liability action. Despite this, the appellate court found that language included in the Tennessee Health Care Liability Act at the time the case was filed created a potential for confusion regarding what constituted a “health care liability action.” In addition, the Court of Appeals stated it believed the woman acted in good faith when filing her case, since she complied with the requirements enumerated in both Sections 29-26-121 and 29-26-122. Since the woman filed her lawsuit expecting in good faith that the statute of limitations would be tolled by 120 days, based on Section 29-26-121(c), the court held it was timely filed.

Since the injured woman’s premises liability complaint was not time-barred, the Court of Appeals of Tennessee at Knoxville vacated the trial court’s order granting summary judgment in favor of the hospital and remanded the case for a trial on the merits.

The experienced advocates at the Hartsoe Law Firm, P.C. are available to help personal injury victims in Knoxville and throughout Eastern Tennessee recover the damages they deserve based on the severity of their harm. To discuss your premises liability or other negligence claim with a hardworking Tennessee personal injury attorney, call the Hartsoe Law Firm, P.C. today at (865) 524-5657 or contact us online.

Additional Resources:

Coggins v. Holston Valley Medical Center, Tenn: Court of Appeals 2015

More Blog Posts:

Knoxville Court Rules Father is Not Barred From Bringing Tort Claim on Behalf of His Injured Child, August 26, 2014, Knoxville Injury Lawyer Blog

Knoxville Appeals Court Holds Plaintiff’s Evidence Was Sufficient to Continue to Trial in Premises Liability Action, July 29, 2014, Knoxville Injury Lawyer Blog


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