Houston Methodist Willowbrook Hospital v. Mary Lou Ramirez, 539 S.W.3d 495

Ramirez was at Houston Methodist Willowbrook for a physician visit and was sent to radiology for a chest x‑ray; while walking between the elevator and radiology she slipped and fell on a floor being buffed with no wet‑floor sign.
She sued the hospital for negligence: permitting the floor to be slippery, failing to remedy the condition, and failing to warn.
The hospital moved to dismiss under the Texas Medical Liability Act (TMLA), arguing the claim is a "health care liability claim" subject to expert‑report requirements that Ramirez did not meet.
The trial court denied the motion to dismiss; the hospital appealed under the TMLA’s accelerated appeal procedure.
The central question was whether Ramirez’s premises‑liability slip‑and‑fall claim qualifies as a health care liability claim under either the TMLA’s "safety" prong or its "professional or administrative services" prong.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the slip‑and‑fall is a TMLA "safety" claim (requires substantive nexus to health care)	Ramirez: Claim is ordinary premises negligence, not tied to health‑care‑specific safety duties	Hospital: Violation of hospital safety/cleanliness regulations and duties shows a nexus to patient safety so TMLA applies	Held: Not a safety‑based health care liability claim — no substantive nexus shown; premises duties were general, not health‑care‑specific
Whether the claim implicates "professional or administrative services directly related to health care" (TMLA category)	Ramirez: Floor maintenance/warnings are ordinary premises duties, not regulatory, license‑dependent health‑care services	Hospital: Maintaining safe, sanitary premises is required for licensing/accreditation and thus is an administrative duty tied to health care	Held: Not within professional/administrative category — hospital failed to show the duties were "directly related" to providing the x‑ray/health care

Am. Transitional Care Ctrs. of Tex., Inc. v. Palacios, 46 S.W.3d 873 (2001) (standard of review and TMLA expert‑report framework)
Bioderm Skin Care, LLC v. Sok, 426 S.W.3d 753 (2014) (de novo review on whether a claim is a health care liability claim)
Ross v. St. Luke’s Episcopal Hosp., 462 S.W.3d 496 (2015) (safety‑standards claims require a substantive nexus to health care; seven‑factor test)
Galvan v. Memorial Hermann Hosp. Sys., 476 S.W.3d 429 (2015) (general premises duties do not convert a claim into a TMLA safety claim)
Reddy v. Veedell, 509 S.W.3d 435 (2016) (burden on movant to prove claim is a health care liability claim)
CHRISTUS Health Gulf Coast v. Carswell, 505 S.W.3d 528 (2016) (definition and scope of "professional or administrative services" under TMLA)