Columbia/CSA-HS Greater Columbia Healthcare System v. So. Carolina Medical Malpractice Liability Joint Underwriting Association

In 1997, Dr. Michael Hayes and Dr. Michael Taillon were working as emergency room physicians at Providence Hospital, presumably as independent contractors. Arthur Sharpe came to the Providence Hospital emergency room complaining of chest pain. Dr. Hayes and Dr. Taillon evaluated Sharpe and diagnosed him as suffering from reflux. Sharpe was discharged. Sharpe had actually suffered a heart attack, which was determined a few days later when he sought further medical care elsewhere. Because of the misdiagnosis, in 1999, Sharpe and his wife filed a medical malpractice and loss of consortium action against Providence Hospital and Dr. Hayes. The Sharpes did not name Dr. Taillon as a defendant. Providence Hospital settled with the Sharpes in 2004. In 2007, Providence Hospital filed this equitable indemnification action against Dr. Taillon and his medical malpractice insurer, The South Carolina Medical Malpractice Liability Joint Underwriting Association (collectively Respondents). Respondents moved for summary judgment on the ground that the medical malpractice statute of repose barred Providence Hospital's claim and the circuit court granted the motion on that basis. Providence Hospital appealed, and the court of appeals affirmed. The issue this case presented for the Supreme Court's review was whether the medical malpractice statute of repose applied to Providence Hospital's indemnity claim. The Court concluded that Providence Hospital's indemnity action was indeed barred by the statute of repose, and as such affirmed the trial court. View "Columbia/CSA-HS Greater Columbia Healthcare System v. So. Carolina Medical Malpractice Liability Joint Underwriting Association" on Justia Law