Andreana Williams, acting as conservator for her mother Michelle Hewett, filed a medical malpractice action against Regency Hospital Company, LLC, Regency Hospital Company of Macon, LLC, and Jacquita Baldwin, APRN. The claims arose from medical care Hewett received following a stroke in September 2020 .
Hewett suffered a stroke in early September 2020, which left her permanently disabled. She initially received treatment at Atrium Health. On September 23, 2020, she was discharged from Atrium and transferred to Regency for long-term care .
During her stay at Regency, staff documented that Hewett developed macroglossia, an enlarged tongue. Medical records indicated that the condition worsened over time. Between September 23 and October 22, 2020, the issue persisted and escalated without resolution .
On October 22, 2020, Hewett was transferred back to Atrium Health. Upon admission, a physician documented that she had severe chronic dental trauma to her tongue caused by repeated biting and chewing without deterrents while at the prior facility. The condition required surgical intervention, and Hewett’s tongue was amputated. She remained hospitalized until December 9, 2020, when she was discharged to a different long-term care facility .
Williams was appointed as Hewett’s conservator and guardian on August 2, 2022. On April 7, 2023, more than two years after the medical care and injury at issue, Williams filed a lawsuit asserting claims for medical malpractice and ordinary negligence against Regency and Baldwin .
The filing occurred outside the standard two-year statute of limitations for medical malpractice actions under Georgia law. Williams stated that the statute of limitations should have been tolled due to Hewett’s mental incompetence. She relied on a statutory provision that allows tolling when an individual is legally incompetent at the time a cause of action accrues .
Regency and Baldwin moved to dismiss the complaint. They maintained that the claims were barred by the statute of limitations and that the tolling provision did not apply in medical malpractice cases due to another statutory provision that prevents tolling for legally incompetent individuals in that context .
In response to the motion to dismiss, Williams raised a constitutional challenge. She maintained that the statute preventing tolling in medical malpractice cases treated mentally incompetent individuals differently from similarly situated individuals in other types of civil claims. She stated that this difference violated the Equal Protection Clause of the Fourteenth Amendment .
Williams acknowledged that a prior decision had addressed a similar issue but presented her arguments as distinct. She focused on the distinction between mentally incompetent individuals bringing medical malpractice claims and those bringing other types of claims. She also referenced legislative purposes such as controlling healthcare costs and limiting stale claims, stating that those purposes were not reasonably advanced by denying tolling in these circumstances .
The trial court reviewed the arguments and granted the motion to dismiss. The court determined that the constitutional issue had already been resolved in prior case law and that the statute applied. The court also determined that the claims did not qualify as ordinary negligence claims .
Williams appealed the trial court’s ruling. The case was transferred to the Court of Appeals of Georgia, which affirmed the dismissal. The appellate court determined that it was bound by the prior decision addressing the same constitutional issue and applied that precedent to the case .
The case then proceeded to the Supreme Court of Georgia, which granted certiorari to address whether the earlier decision controlled the outcome and whether the statute violated equal protection principles.
The court reviewed the case under a de novo standard, evaluating the motion to dismiss and construing the complaint in favor of Williams. The court considered whether the statutory classification involving mentally incompetent individuals in medical malpractice cases lacked a rational basis when compared to other civil claims .
The court examined the prior decision that addressed the same statutory provision. In that earlier case, the court had applied rational basis review and determined that the statute was related to legislative objectives such as maintaining access to healthcare and limiting stale claims.
The court determined that the distinctions raised by Williams did not materially differ from those addressed in the prior case. The classification at issue remained the same, involving mentally incompetent individuals bringing medical malpractice claims compared to those bringing other types of claims .
The court also reviewed Williams’s additional arguments regarding other statutory provisions, including requirements for expert affidavits and statutes of repose. Williams stated that these provisions served similar purposes and made the non-tolling statute unnecessary.
The court examined these arguments and found that they had either been addressed in the earlier case or did not alter the constitutional analysis. The court noted that the legislature may address policy concerns through multiple statutory approaches and that the presence of other provisions did not negate the rational basis for the statute at issue .
The Supreme Court of Georgia concluded that the prior decision controlled the outcome of the case and that the statutory provision preventing tolling in medical malpractice actions did not violate the Equal Protection Clause. The court determined that Williams had not met the burden required to show that the statute lacked a rational basis.
The court affirmed the judgment of the Court of Appeals, which upheld the dismissal of the claims as barred by the statute of limitations .
If you are dealing with concerns related to medical treatment or care, our team handles matters involving medical malpractice claims, including cases involving negligence by healthcare providers and resulting injuries. Contact us to learn how we can assist with your matter.