Most medical malpractice claims fall under state law, but federal jurisdiction may arise in certain circumstances. In other words, if you suffered harm due to the negligence of a medical professional in a federal or correctional facility, you may need to navigate both state and federal legal frameworks. As demonstrated in a recent New York case, federal courts sometimes dismiss claims to allow plaintiffs to pursue remedies under state law. If you suffered losses due to medical malpractice, it is wise to speak with a Rochester medical malpractice lawyer about your options to ensure that you do not waive your right to pursue damages.
History of the Case
It is alleged that the plaintiff brought a pro se action under 42 U.S.C. § 1983, alleging medical malpractice and negligence claims against several medical professionals. The plaintiff asserted that during a surgery performed at a hospital to correct a fractured jaw, a nerve was mistakenly severed, causing severe and ongoing pain, numbness, and speech impairment. The plaintiff further alleged that the defendants, including doctors and hospital administrators, negligently discharged him despite his ongoing medical issues. He sought $250,000 in damages.
Reportedly, the federal court granted the plaintiff’s request to proceed in forma pauperis but, upon review, dismissed the case for failure to state a claim. The court provided the plaintiff leave to amend his complaint to address deficiencies, including the failure to allege deliberate indifference to medical needs as required under § 1983. The court also declined to exercise supplemental jurisdiction over the state law claims, citing the dismissal of the federal claims as its basis.
Federal Jurisdiction and State Medical Malpractice Claims
The federal court noted that while medical malpractice claims generally fall under state law, the plaintiff attempted to assert a federal claim by alleging deliberate indifference to his medical needs in violation of constitutional rights. The court outlined the requirements for such claims, explaining that the plaintiff must establish both an objectively serious medical condition and a subjective awareness of and disregard for the risk by the defendants.
Here, the court found that the plaintiff failed to allege facts showing that the defendants acted with the requisite intent. Specifically, while the plaintiff asserted that his injuries were caused by a severed nerve during surgery, the allegations suggested negligence rather than deliberate indifference. Similarly, the discharge decisions made by the medical staff were characterized as exercises of professional judgment, not as actions intended to harm the plaintiff or disregard his health.
Turning to the state law claims, the court declined to retain jurisdiction. It explained that under the Federal Rules of Civil Procedure, federal courts may dismiss supplemental state law claims when the federal claims providing original jurisdiction are dismissed early in the proceedings. The court emphasized the importance of allowing state courts to resolve such issues, especially when the claims primarily involve questions of professional negligence under state standards of care.
Meet with an Experienced Rochester Medical Malpractice Lawyer
If you were harmed by the negligence of a doctor or other medical provider, you may be owed damages under state law. The experienced Rochester medical malpractice attorneys at DeFrancisco & Falgiatano Personal Injury Lawyers can assess your case and help you pursue appropriate compensation. You can reach us by calling 833-200-2000 or filling out our online form to arrange a consultation.