PHILADELPHIA – A Philadelphia federal court has declined to exercise supplemental jurisdiction over state law claims, brought by the estate of a man who suffered a severe medical episode and died in custody at the Montgomery County Correctional Facility.
U.S. District Court for the Eastern District of Pennsylvania Judge Joshua D. Wolson ruled May 10 that for lack of jurisdiction, it would not consider state law medical negligence claims from the Estate of Terrence T. Taylor, leveled against Montgomery County, numerous corrections officers, nurses and doctors.
“On Oct. 28, 2017, Terrence Taylor suffered a severe medical episode and died in custody at the Montgomery County Correctional Facility in Eagleville, Pennsylvania. Nearly two years later, on Oct. 22, 2019, Mr. Taylor’s Estate brought suit against Montgomery County, a host of correctional officers, and their supervisors for violations of Mr. Taylor’s constitutional rights, pursuant to 42 U.S.C. Section 1983,” Wolson said.
“The Taylor Estate also asserted claims for medical negligence under Pennsylvania law against the hospital where Mr. Taylor received treatment earlier in the day, as well as PrimeCare Medical, Inc., the prison’s medical provider, and PrimeCare personnel who were working in the prison on the day that Mr. Taylor died, including Dr. Margaret Carrillo, Claudette Foster, R.N., Thomas Reece, LPN, and Judith McIlhorne, R.N.”
After a period of discovery, both the County defendants the PrimeCare defendants filed motions for summary judgment.
“On April 20, 2021, while the dispositive motions were pending, the Taylor Estate settled its claims against the County defendants, and the Court dismissed the Section 1983 claims with prejudice,” Wolson said.
“The following day, in light of the fact that the Section 1983 claims had been dismissed, the Court issued an order directing the parties to address whether the Court should dismiss the Taylor Estate’s remaining state law claim against the PrimeCare defendants or whether there is an affirmative justification for the Court to continue exercising supplemental jurisdiction over that claim.”
Wolson explained that the U.S. Court of Appeals for the Third Circuit’s decision in Hedges v. Musco “created a presumption that a court will decline to exercise supplemental jurisdiction once it disposes of all federal claims, unless the case is an unusual one.”
According to Wolson, the Taylor Estate offered several justifications for the Court to retain jurisdiction in this case, but “each was a justification that arises in almost every case, rather than something that sets this case apart.”
“First, the Court has had only limited involvement in this case. It has resolved two substantive motions and a single discovery dispute. That investment of time does not create the sort of judicial knowledge of the case to take this case out of the ordinary,” Wolson stated.
“Second, the Court disagrees with the Taylor Estate’s assertion that the trial in this action will necessarily introduce evidence that requires an analysis of the Taylor Estate’s federal claims against the County defendants. Even if it does, state courts have concurrent jurisdiction over claims arising under Section 1983, so a state court can provide appropriate instruction to the jury on how to factor in the claims against the County defendants. In fact, the state court will be better situated than this Court to assess how the settlement of federal claims impacts ongoing claims that arise under state law.”
Wolson continued that concerns of fairness and prejudice are not ably supported.
“Third, there is no trial on the immediate horizon, so possible delay of a trial does not pose the sort of fairness concerns that might set this case apart. There will almost always be some amount of delay and inconvenience in a case after a federal court dismisses supplemental state law claims. The Taylor Estate’s concerns about delay, where the sole beneficiary is Mr. Taylor’s minor daughter, are understandable. However, the significant delay facing this case stems from the COVID-19 pandemic, rather than the dismissal of the remaining claim. Unfortunately, the Taylor Estate will have to continue to wait for a trial date, regardless of where the case is pending. And that would be true for any case suffering Covid-related delays, not just this one” Wolson said.
“Fourth, even though the Taylor Estate will have to re-file its complaint and re-serve the PrimeCare defendants, it will not be starting the case anew. Fact discovery is complete, and the PrimeCare defendants’ summary judgment motion is teed-up for resolution. While it is true that the Taylor Estate will not have an opportunity to depose the PrimeCare defendants’ expert(s) in state court (as a result of an agreement between the parties not to depose experts until after the summary judgment ruling), the Taylor Estate will not be prejudiced as a result, because the PrimeCare defendants are subject to the same rule.”
Wolson ruled that the Court would not extend jurisdiction over the state law claims.
“The factors that the Taylor Estate cites are factors that arise in every case where federal claims get resolved and a court declines to exercise supplemental jurisdiction over remaining state law claims. If those claims arise as a matter of course, they cannot overcome the Third Circuit’s mandate to dismiss cases in the ordinary course,” Wolson concluded.
U.S. District Court for the Eastern District of Pennsylvania case 2:19-cv-04921
From the Pennsylvania Record: Reach Courts Reporter Nicholas Malfitano at nick.malfitano@therecordinc.com