Cecilia M. Simmons v. Outreach Health Community Care Services, LP. D/B/A Outreach Health Services
Cecilia Simmons, a certified nursing assistant, sued her employer, Outreach Health Community Care Services, for injuries sustained while moving a quadriplegic patient. Simmons alleged a breach of duty to provide a safe work environment. The trial court dismissed her claim with prejudice, deeming it a health care liability claim (HCLC) under the Texas Medical Liability Act (TMLA) that required an expert report, which Simmons failed to provide. On appeal, the court affirmed the dismissal, finding Simmons's claim constituted a breach of safety standards HCLC because her injury occurred while rendering health care services to a patient, and her constitutional challenges to the TMLA's expert report requirement were without merit.