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Keywords

defendantjurisdictiontrialdue process

defendantjurisdictionappealtrialmotionsummary judgmentdue processmotion for summary judgment

Related Cases

Presbyterian University Hosp. v. Wilson, 337 Md. 541, 654 A.2d 1324, 63 USLW 2581, 99 Ed. Law Rep. 481

Facts

Hugh Eric Wilson, a Maryland resident, was diagnosed with non-alcoholic cirrhosis of the liver and required a liver transplant. His wife contacted various health organizations to inquire about coverage, but was informed that coverage was not available. Despite this, Dr. Starzl at Presbyterian University Hospital agreed to admit Mr. Wilson. However, upon arrival, he was refused admittance due to lack of confirmed insurance coverage. After several attempts to secure coverage, Mr. Wilson was admitted under his union insurance but died before he could receive the transplant.

This case arises out of the tragic death of Hugh Eric Wilson. In January of 1985, Mr. Wilson was diagnosed by Dr. Martin B. Cooper, a Maryland gastroenterologist, with non-alcoholic cirrhosis of the liver. Mr. Wilson and his wife were informed that this condition would be fatal without a liver transplant.

Issue

Whether the Due Process Clause of the Fourteenth Amendment permits a Maryland court to exercise personal jurisdiction over a Pennsylvania hospital that provided services to a Maryland resident in Pennsylvania.

In the present case, we must determine whether the Due Process Clause of the Fourteenth Amendment permits a Maryland court to exercise personal jurisdiction over a Pennsylvania hospital that provided services to a Maryland resident in Pennsylvania.

Rule

The exercise of personal jurisdiction requires that a defendant have 'minimum contacts' with the forum state, and that the exercise of jurisdiction does not offend 'traditional notions of fair play and substantial justice.'

The Supreme Court requires a defendant to have 'minimum contacts' with the forum state for personal jurisdiction to attach and that the exercise of jurisdiction should not offend 'traditional notions of fair play and substantial justice.'

Analysis

The court found that the hospital had sufficient contacts with Maryland to justify the exercise of specific personal jurisdiction. The hospital's registration as a Maryland Medical Assistance provider and its designation as a transplant referral center indicated that it had purposefully availed itself of the benefits of conducting business in Maryland. The court noted that the hospital's actions, including discussions with Maryland insurers and arrangements for Mr. Wilson's treatment, established a direct connection to the cause of action.

The trial judge, in denying the motion for summary judgment, found 'from the facts' that there was the necessary purposeful availment on the part of PUH to support the exercise of personal jurisdiction over the hospital.

Conclusion

The court affirmed the trial court's decision, holding that the exercise of personal jurisdiction over the hospital did not violate due process.

Affirmed.

Who won?

The Wilsons prevailed in the case because the court found that the hospital had sufficient contacts with Maryland to justify the exercise of personal jurisdiction.

The Court of Special Appeals affirmed the trial court's conclusion that it could exercise personal jurisdiction over hospital, and hospital sought further review.

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