Irving W. Marks v. St. Luke's Episcopal Hospital
Irving W. Marks, a patient recovering from back surgery at St. Luke’s Hospital, fell when the bed's footboard came loose. He sued the hospital, alleging ordinary negligence and health care liability claims. The Supreme Court of Texas examined whether the claim regarding the defective footboard was a health care liability claim under the Medical Liability and Insurance Improvement Act (MLIIA), which would require an expert report. The Court concluded that the claim concerning the defective hospital bed footboard was ordinary negligence, not a health care liability claim, as it did not involve medical or professional judgment. However, Marks's other claims alleging negligent care and supervision were deemed health care liability claims. The Court affirmed in part and reversed in part, remanding the case to the trial court, and denied Marks's request for a grace period to file an expert report for the health care liability claims due to insufficient evidence of accident or mistake.