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Hayward v. Valley Vista Care Corp.9/28/2001
Coeur d'Alene, April 2001 Term
2001 Opinion No. 85
Appeal from the District Court of the First Judicial District of the State of Idaho, Benewah County. Hon. Craig C. Kosonen, District Judge.
Alfred S. Hayward (Alfred), personal representative of his father's estate, appeals the lower court's ruling denying Alfred's motion to amend his state court complaint to add a wrongful death claim and the lower court's ruling granting summary judgment dismissal of Alfred's remaining state court claims.
I. FACTS AND PROCEDURAL HISTORY
Delbert Hayward (Delbert), an eighty-five-year-old resident of North Idaho, lived at his home in Emida, Idaho, with the assistance of home health care providers. In order to continue the home health care services, the Idaho Department of Health and Welfare required Delbert to submit to periodic medical evaluations.
Delbert was admitted into Kootenai Medical Center on February 22, 1994, in order for the required evaluation to be conducted. On March 4, 1994, Delbert was released to a personal care home in Hayden Lake, Idaho. He was admitted back into Kootenai Medical Center on March 10, 1994, when he refused to eat and wanted to return to his home. After being discharged from Kootenai Medical Center for the second time, Delbert was admitted to Valley Vista Care Center (Valley Vista), a nursing home facility in St. Maries, Idaho. He resided at Valley Vista from March 11, 1994, until his death on February 16, 1995.
On February 14, 1997, Alfred S. Hayward, a surviving son of the decedent and a resident of Oregon, filed two complaints. One, a wrongful death action, was filed in federal district court. The other, a complaint consisting primarily of contractual allegations, was filed in state court. The state court complaint was brought on behalf of the estate of Delbert Hayward and sought to recover medical expenses. Both complaints contained identical factual allegations. The defendants named in both complaints were Valley Vista and various health care professionals that provided services to Valley Vista.
In Alfred's complaint, he claimed that his father was falsely imprisoned in the nursing home and that the negligent care he received there, including the injection of high dosages of the drug Haldol, attributed to his father's death. Alfred also alleged that the defendants breached duties imposed on them by the terms of Alfred's admission agreement, as well as duties imposed under federal and state law. Alfred's wrongful death claim filed in federal district court asserted diversity of citizenship, based on the fact that Alfred was a resident of Oregon, his brother and sister were residents of Washington, and the defendants were all residents of Idaho.
On March 10, 1997, the defendants moved to dismiss the federal court action based on lack of diversity jurisdiction and because there were "identical wrongful death claims in both courts." The defendants argued that diversity could not be maintained since a personal representative is deemed to be a resident of the decedent's state of residency. In this case, since Delbert was a resident of Idaho, Alfred's state of residency was also Idaho. Consequently, the diversity requirements were no longer satisfied.
On February 6, 1998, the federal court granted a motion filed by Alfred to amend the complaint (to change the plaintiff's status from personal representative to heir) and denied the defendants' motion to dismiss. On June 8, 1998, Alfred moved the federal court to exercise supplemental jurisdiction over the state court claim for breach of contract. The federal court declined to do so on November 18, 1998.
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