Exhaustion Requirements in Federal Medical Malpractice Claims

People who suffer harm due to medical care provided by federally funded healthcare providers will typically pursue medical malpractice claims against them under the Federal Tort Claims Act. If they do, it is critical for them to abide by any procedural requirements. It is important to note, though, that there is a distinction between statutory jurisdictional requirements and agency-specific procedural regulations, as discussed in a recent Maryland medical malpractice case in which the court affirmed that only statutory provisions dictated the jurisdictional bounds for Federal Tort Claims Act claims. If you were harmed by incompetent medical care at a federal facility, it is wise to speak to a Baltimore medical malpractice attorney about your rights.

Setting of the Case

It is reported that the plaintiffs, the decedent’s estate, spouse, and five children, filed a lawsuit under the Federal Tort Claims Act following the death of the decedent after medical treatment at a military medical center. Each plaintiff sought 25,000,000 in damages, except for one plaintiff who did not specify damages. The plaintiffs initially submitted administrative claims to the military, alleging negligence and seeking damages for wrongful death and survival, which the military subsequently denied.

It is alleged that the defendants moved to dismiss the plaintiff’s claims for the case for lack of subject matter jurisdiction, citing failure to meet the Federal Tort Claims Act’s administrative exhaustion requirements, particularly regarding the qualifications of the estate’s representative at the time of claim submission. The court granted the motion, and the plaintiffs appealed.

Exhaustion Requirements in Federal Medical Malpractice Claims

On appeal, the court reviewed the district court’s dismissal, focusing on whether plaintiffs satisfied the Federal Tort Claims Act’s administrative exhaustion requirements. The court held that the statutory text of the applicable law establishes the sole jurisdictional prerequisites for Federal Tort Claims Act claims, including presenting the claim to the agency, stating the claim amount, and awaiting final agency denial or six months of inaction. These requirements, the court emphasized, were statutory and jurisdictional in nature.

The court rejected the government’s argument that additional jurisdictional requirements were imposed by military regulations. It clarified that such regulations were distinct from the jurisdictional requirements delineated in § 2675. Thus, failure to comply with military-specific regulations did not affect the jurisdiction of federal courts over Federal Tort Claims Act claims.

Thus, the court found that all plaintiffs, except one, had satisfied the Federal Tort Claims Act’s jurisdictional prerequisites, thereby reversing the district court’s dismissal as to six plaintiffs and remanding for further proceedings. The exception was one plaintiff who did not meet the jurisdictional requirement of specifying damages in her administrative claim. Therefore, the court affirmed the dismissal as to her claims.

Meet with a Competent Maryland Medical Malpractice Attorney

If you suffered injuries because of a physician’s error, it is wise to meet with a lawyer to assess the compensation you may be able to recover. The competent Baltimore medical malpractice lawyers at Arfaa Law Group can examine your potential claims and aid you in seeking justice. To schedule a conference, contact us via our online form or call (410) 889-1850.

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