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Jones v. Missouri Baptist Medical Center

Citations: 496 S.W.3d 596; 2016 Mo. App. LEXIS 431; 2016 WL 1917022Docket: No. ED 103041

Court: Missouri Court of Appeals; May 3, 2016; Missouri; State Appellate Court

Narrative Opinion Summary

In this case, the plaintiff filed a medical malpractice lawsuit against multiple healthcare entities, which was dismissed by the trial court as barred by the statute of limitations under Missouri Revised Statutes Section 516.105. The plaintiff appealed, arguing that her mental incapacity should toll the limitations period, that her case was timely refiled under the savings statute (Section 516.230), and that any statutory interpretation barring her claim was unconstitutional. The appellate court reviewed the briefs and the record and found no merit in the plaintiff's arguments. The court concluded that the trial court correctly applied the statute of limitations and that the provisions for tolling due to mental incapacity did not apply. Furthermore, the court dismissed the constitutional challenge to the interpretation of the statutes. The appellate court affirmed the trial court's decision without issuing a full opinion, as the case was deemed not to have precedential value, but provided a memorandum opinion to the parties, thereby upholding the dismissal of the medical malpractice action.

Legal Issues Addressed

Affirmation of Trial Court Judgment

Application: The appellate court affirmed the trial court's dismissal of the case, finding no merit in the appellant's claims of error.

Reasoning: The court affirmed the trial court's judgment according to Rule 84.16(b).

Application of the Savings Statute RSMo 516.230

Application: The plaintiff's contention that her case was timely refiled under the savings statute was found to be without merit.

Reasoning: She contended that her case was timely refiled under the savings statute, 516.230.

Constitutionality of Statutory Interpretation

Application: The appellate court rejected the plaintiff's argument that any interpretation of the statutes barring her claim was unconstitutional.

Reasoning: She claimed that any interpretation of 516.170 and 516.105 barring her claim was unconstitutional.

Statute of Limitations under RSMo 516.105

Application: The trial court applied the two-year statute of limitations to dismiss the medical malpractice action, concluding it was barred by the statute of limitations.

Reasoning: The trial court dismissed Voncile Jones's medical malpractice action against Balias Anesthesia, Inc., Missouri Baptist Medical Center, BJC Health Systems, and BJC Healthcare, ruling that the petition was barred by the statute of limitations under RSMo 516.105.

Tolling of Statute of Limitations due to Mental Incapacity

Application: The court determined that the statute did not toll the limitations period despite the plaintiff's claim of continuing mental incapacity.

Reasoning: She argued that her continuing mental incapacity should toll the two-year statute of limitations set forth in 516.105.