A physician practicing solely in New Jersey had sufficient minimum contacts with Pennsylvania to establish personal jurisdiction.
The plaintiff brought this action following the death of her 15-year-old son, Michael. She alleged that the defendant doctor, who had been treating Michael for a heart murmur since he was four years old, negligently failed to place any restrictions on Michael’s athletic activity, which ultimately caused Michael’s death when he had a cardiac arrest while playing roller hockey. In response to the plaintiff’s complaint, the defendant filed preliminary objections and argued that Pennsylvania lacked jurisdiction over him because he practiced medicine solely in New Jersey and only saw Michael at his office, which is located in New Jersey. Ultimately, relying on the well-known case International Shoe Co. v. Washington, the court held that the defendant had sufficient minimum contacts with Pennsylvania to establish jurisdiction in Pennsylvania. The court justified its holding by noting that the defendant was part of a Pennsylvania-based network of health care services (Children’s Hospital of Philadelphia), the entire financial aspect of the defendant’s relationship with Michael involved bills generated in Pennsylvania, payments received from Michael’s insurance company were received at a Pennsylvania location, on multiple occasions the defendant sent Michael to a Pennsylvania hospital for treatment, and the defendant intentionally affiliated himself with a Pennsylvania hospital. Additionally, because of these same facts, the court held that it was not a substantial burden on the defendant to be expected to come to court in Pennsylvania.
Case Law Alert, 1st Quarter 2014