Costin v. Glens Falls Hospital
1:22-cv-00296
N.D.N.Y.Dec 4, 2024Background
- Nicole Costin, on behalf of herself and her minor son Baby A, brought suit alleging violations of the ADA, Rehabilitation Act, and several state law claims arising from her childbirth experience at Glens Falls Hospital.
- After an initial dismissal of federal claims (and associated state law claims on supplemental jurisdiction grounds), the Second Circuit vacated dismissal of the ADA/RA claims, remanding the case and restoring jurisdiction over state law claims.
- Two individual defendants, Karen Ranttila (Registered Nurse) and Nicole Bennett (Student Nurse Midwife at the time), moved to dismiss state law tort claims specifically against them.
- Legally relevant facts include: drug testing conducted without consent, withholding of anesthesia during labor, alleged unnecessary use of Pitocin, and post-birth separation of mother and Baby A for additional testing without consent.
- Plaintiff asserts medical malpractice (including lack of informed consent), assault and battery, and intentional/negligent infliction of emotional distress based on the above conduct.
- The Court’s decision addresses the sufficiency of the pleadings under Rule 12(b)(6), accepting factual allegations as true at this stage.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Assault & Battery by Bennett | Bennett touched/treated Plaintiff without consent and over her objection | Treatment was medically necessary and covered by a signed consent form | Denied dismissal; issue of consent not resolvable at this stage |
| Medical Malpractice by Ranttila | Deviation from standard of care led to injury, including forced labor, | Plaintiff fails to allege actionable injury proximately caused by Ranttila's conduct | Denied dismissal; plausible claim stated |
| Lack of Informed Consent by Ranttila | Pitocin administered, labor induced, and pain relief withheld without | Collecting samples doesn’t require consent; Ranttila didn’t make key decisions | Denied dismissal; plausible claim stated |
| Emotional Distress Claims (Intentional & Negligent) | Severe distress caused by defendants’ conduct, pled in alternative | Claims duplicative of malpractice; no extreme/outrageous conduct; no threat to safety | Denied dismissal; alternative pleading allowed; sufficient at this stage |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard for Rule 12(b)(6) motions)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (articulates "plausibility" standard for pleadings)
- Armstrong ex rel. Armstrong v. Brookdale Univ. Hosp. & Med. Ctr., 425 F.3d 126 (battery in medical context requires absence of consent)
- Derdiarian v. Felix Contracting Corp., 51 N.Y.2d 308 (proximate cause and intervening acts in tort)
- Benitez v. N.Y.C. Bd. of Educ., 73 N.Y.2d 650 (proximate cause is generally a question of fact)