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Keywords

contractbreach of contractplaintiffdefendantattorneystatutehearingmotionsummary judgmentdiscriminationbad faith
plaintiffdefendantlitigationattorneystatutehearingmotionsummary judgmentwilldiscriminationbad faithcommon lawdeclaratory judgmentpiracy

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Jenkins v. Methodist Hospitals of Dallas Inc., Not Reported in F.Supp.2d, 2009 WL 2776478

Facts

The case arose from a dispute where the Defendants sought to recover attorneys' fees under the Health Care Quality Immunity Act (HCQIA), the Texas Medical Practices Act (TMPA), and 42 U.S.C. § 1988(b) after the Plaintiff's claims were dismissed. The court noted that the Plaintiff's claims included allegations of race discrimination, intentional infliction of emotional distress, and breach of contract, among others. Many of these claims were dismissed at the summary judgment hearing due to lack of evidence or were voluntarily withdrawn by the Plaintiff.

The Court found that the individual Defendants were immune under the TMPA or, in the case of Meeks, because the Plaintiff presented no factual basis for the claims against Meeks. Claims for race discrimination in employment, declaratory judgment, intentional infliction of emotional distress, common law conspiracy and under 42 U.S.C. § 1985. These claims were all dismissed at the summary judgment hearing either because they were voluntarily withdrawn by the Plaintiff, were dismissed because there was no response by the Plaintiff to the summary judgment motion on such claims, or because the Plaintiff had no evidence to support such claims.

Issue

Did the Plaintiff's claims warrant the award of attorneys' fees to the Defendants under the HCQIA, TMPA, and 42 U.S.C. § 1988(b)?

Did the Plaintiff's claims warrant the award of attorneys' fees to the Defendants under the HCQIA, TMPA, and 42 U.S.C. § 1988(b)?

Rule

Under the HCQIA, attorneys' fees may be awarded if the statute's standards of immunity are met, the defendants substantially prevailed, and the plaintiff's claim was frivolous, unreasonable, without foundation, or in bad faith. The TMPA and 42 U.S.C. § 1988(b) allow for discretionary fee awards if the claim is frivolous, unreasonable, or without foundation.

The Court notes that under the HCQIA, such fees are to be awarded when (1) the statute's standards of immunity were met; (2) defendants substantially prevailed; and (3) the plaintiff's claim or conduct during the litigation was frivolous, unreasonable, without foundation or in bad faith.

Analysis

The court analyzed the claims made by the Plaintiff and determined that while some claims were unreasonable and without foundation, the overall conduct of the Plaintiff did not meet the threshold of being frivolous or in bad faith. The court concluded that one third of the fees incurred by the Defendants were attributable to the unreasonable claims, justifying a partial award of attorneys' fees.

The Court cannot conclude based on the law, and all of the evidence before it, that the Plaintiff's overall litigation conduct was frivolous, unreasonable, without foundation or in bad faith; however, the Court concludes that the claims described below were unreasonable and without foundation, and that a portion of the fees incurred are attributable to such claims and should be awarded in favor of Defendants.

Conclusion

The court granted the Defendants' Motion in part, awarding them $112,000 in reasonable and necessary attorneys' fees.

The Court therefore GRANTS Defendants' Motion in part. The Court will award Defendants a reasonable and necessary attorneys fee of $112,000.

Who won?

The Defendants prevailed in the case as the court found that a portion of the Plaintiff's claims were unreasonable and without foundation, justifying the award of attorneys' fees.

The Court therefore concludes that one third of the fees incurred by the Defendants were attributable to claims asserted as to which Plaintiff's positions were unreasonable and without foundation.

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