Medical City Dallas Hospital, Inc. and Columbia Hospital at Medical City Dallas Subsidiary, L.P. v. Ardell Williams, 05-14-00664-CV

Ardell Williams visited a relative at Medical City Dallas and allegedly slipped on a puddle of water exiting an elevator, suffering injuries.
Williams sued Medical City Dallas Hospital, Inc. and Columbia Hospital at Medical City Dallas Subsidiary, L.P. (collectively, Hospitals) for negligence.
Hospitals moved to dismiss under Tex. Civ. Prac. & Rem. Code § 74.351, arguing the claim is a "health care liability claim" and Williams failed to serve the required expert report within 120 days.
The trial court denied the Hospitals’ motion to dismiss; Hospitals appealed the interlocutory order.
The Court of Appeals considered whether Williams’s premises-slip claim was subject to Chapter 74’s expert-report requirement.
The court concluded the claim was not a health care liability claim because it was not directly or indirectly related to health care; it was a personal, non-derivative premises negligence claim occurring at a hospital.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Williams’s slip-and-fall negligence claim is a "health care liability claim" under § 74.001(a)(13)	Williams: Her claim is ordinary premises negligence, not tied to medical treatment or services	Hospitals: The alleged failure to keep premises safe is a "safety" claim within Chapter 74 and thus requires an expert report	Court: Not a health care liability claim; Chapter 74 does not apply

DHS Mgmt. Serv., Inc. v. Castro, 435 S.W.3d 919 (Tex. App.—Dallas 2014) (premises claims at hospitals require an indirect relationship to health care to fall under Chapter 74)
Baylor Univ. Med. Ctr. v. Lawton, 442 S.W.3d 483 (Tex. App.—Dallas 2013) (mere occurrence of injury at hospital insufficient to convert ordinary negligence into a health care liability claim)

Affirmed: the trial court’s denial of the Hospitals’ motion to dismiss; Williams awarded appellate costs.