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Yanakos v. UPMC, 655 Pa. 615, 218 A.3d 1214

Facts

Susan Yanakos, suffering from Alpha-1 Antitrypsin Deficiency, required a liver transplant. Her son Christopher volunteered to be a donor, but the physician, Dr. Shaw-Stiffel, failed to inform him that he had the same genetic condition and was not a suitable donor. The transplant proceeded in September 2003. Over a decade later, the Yanakoses discovered that Susan still had the condition, leading them to sue UPMC and the involved physicians for medical malpractice, among other claims. The defendants argued that the claims were barred by the MCARE Act's seven-year statute of repose.

Susan Yanakos, suffering from Alpha-1 Antitrypsin Deficiency, required a liver transplant. Her son Christopher volunteered to be a donor, but the physician, Dr. Shaw-Stiffel, failed to inform him that he had the same genetic condition and was not a suitable donor.

Issue

Does the seven-year statute of repose in the MCARE Act violate Article I, Section 11 of the Pennsylvania Constitution, which guarantees a right to a remedy?

Does the seven-year statute of repose in the MCARE Act violate Article I, Section 11 of the Pennsylvania Constitution, which guarantees a right to a remedy?

Rule

The Pennsylvania Constitution guarantees that 'all courts shall be open; and every man for an injury done him… shall have remedy by due course of law.' Statutes that infringe on this right are subject to intermediate scrutiny to determine if they are substantially related to an important government interest.

The Pennsylvania Constitution guarantees that 'all courts shall be open; and every man for an injury done him… shall have remedy by due course of law.'

Analysis

The court applied intermediate scrutiny to evaluate the MCARE Act's statute of repose, concluding that while controlling medical malpractice insurance costs is an important government interest, the seven-year limit is not substantially related to that goal. The court noted that the statute's exceptions for foreign objects and minors undermine its purpose by leaving insurers exposed to unpredictable claims, thus failing to provide the actuarial certainty intended.

The court applied intermediate scrutiny to evaluate the MCARE Act's statute of repose, concluding that while controlling medical malpractice insurance costs is an important government interest, the seven-year limit is not substantially related to that goal.

Conclusion

The Supreme Court reversed the Superior Court's decision, declaring the MCARE Act's seven-year statute of repose unconstitutional and remanding the case for further proceedings.

The Supreme Court reversed the Superior Court's decision, declaring the MCARE Act's seven-year statute of repose unconstitutional and remanding the case for further proceedings.

Who won?

The Yanakoses prevailed in the case as the Supreme Court found the statute of repose unconstitutional, allowing their claims to proceed.

The Yanakoses prevailed in the case as the Supreme Court found the statute of repose unconstitutional, allowing their claims to proceed.

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