Terry Kuchera v. Jersey Shore Family Health Center (073483)
111 A.3d 84
N.J.2015Background
- On March 7, 2009, plaintiff Terry Kuchera slipped and fell on a tile floor at a free eye‑screening held at Jersey Shore Family Health Center (Family Health Center), an outpatient clinic affiliated with Jersey Shore University Medical Center (Medical Center) and Meridian Health. She alleged significant injuries and sued the Family Health Center, the Medical Center, Meridian Health, and the property owner.
- Meridian Health and its hospitals are nonprofit 501(c)(3) organizations; their certificates of incorporation state purposes including operating hospitals, providing charity care, and conducting educational and research programs.
- The trial court and Appellate Division held Meridian Health was a hybrid institution (hospital plus charitable/educational functions) and therefore entitled to absolute charitable immunity under N.J.S.A. 2A:53A-7. Summary judgment for defendants was entered and affirmed.
- The central legal question on certification was statutory: whether the defendants are covered by charitable immunity for entities organized exclusively for charitable/educational/religious purposes (N.J.S.A. 2A:53A-7) or instead are nonprofit institutions organized exclusively for hospital purposes that are liable for negligence but subject to a capped recovery (N.J.S.A. 2A:53A-8).
- The Supreme Court reversed the Appellate Division, holding the Medical Center and its Family Health Center are organized exclusively for hospital purposes (in the statutory sense) and therefore are not absolutely immune but are subject to the section 8 limited liability (damages cap).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the health‑care facility is entitled to absolute charitable immunity under N.J.S.A. 2A:53A-7 or instead to limited hospital liability under N.J.S.A. 2A:53A-8 | Kuchera: Meridian Health hospitals are "organized exclusively for hospital purposes," and hospital purposes include teaching, community clinics, and charity care; thus section 8 applies and defendants are liable with damages capped. | Defendants: The hospital performs charitable and educational activities; because it provides charity clinics and sponsors events (like the screening), it is a hybrid entity and entitled to absolute immunity under section 7; analysis should focus on the specific use of the facility at the time of the incident. | Court: Reversed — the modern hospital’s core functions include outpatient clinics, teaching, and charity care; the Medical Center and Family Health Center fall under section 8 (limited liability, not absolute immunity). |
Key Cases Cited
- Hunterdon Med. Ctr. v. Twp. of Readington, 195 N.J. 549 (2008) (modern hospital purposes include a broad range of inpatient and outpatient services and the site of service need not be on main campus to be a hospital purpose)
- Benton v. Young Men’s Christian Ass’n of Westfield, 27 N.J. 67 (1958) (abolition of common-law charitable immunity by the Court)
- Collopy v. Newark Eye & Ear Infirmary, 27 N.J. 29 (1958) (same year cases addressing charitable immunity principle)
- Dalton v. St. Luke’s Catholic Church, 27 N.J. 22 (1958) (same year cases addressing charitable immunity principle)
- Lawlor v. Cloverleaf Mem’l Park, 56 N.J. 326 (1970) (discussing legislative response restoring charitable immunity by statute)
- Bieker v. Cmty. House of Moorestown, 169 N.J. 167 (2001) (an entity’s stated nonprofit purpose controls but factual inquiry required to determine whether activities are consistent with that purpose)
- Hardwicke v. Am. Boychoir Sch., 188 N.J. 69 (2006) (statutory beneficiary requirement and purpose‑focused analysis under the Act)