Gliemmo v. Cousineau

BENHAM, Justice,

dissenting.

The Georgia Constitution prohibits the General Assembly from enacting a “local or special law ... in any case for which provision has been made by an existing general law. . . .” 1983 Ga. Const., Art. Ill, Sec. VI, Par. IV (a). Since 1863, Georgia law has required that “[a] person professing to practice surgery or the administering of medicine for compensation must bring to the exercise of his profession a reasonable degree of care and skill[,]” and Georgia law has provided that “[a]ny injury resulting from a want of such care and skill shall be a tort for which recovery may be had.” OCGA § 51-1-27. In 2005, the General Assembly enacted OCGA § 51-1-29.5 (c), which provides that certain physicians and health care providers in certain situations are not liable unless they are shown to have been grossly negligent. The majority concludes that the new law is a constitutional general law. I respectfully dissent because I believe the 2005 law is a special law that is unconstitutional on two grounds: the General Assembly previously enacted a general law concerning the standard of care to which medical personnel must adhere to avoid liability; and the classification of those affected by the new legislation is unreasonable.

1. “The broad objective” of the constitutional provision is “to insure that once the legislature entered a field by enacting a general law, that field must thereafter be reserved exclusively to general *14legislation and could not be open to special or local laws.” City of Atlanta v. Hudgins, 193 Ga. 618, 623 (19 SE2d 508) (1942). See also Franklin County v. Fieldale Farms Corp., 270 Ga. 272 (2) (507 SE2d 460) (1998) (the uniformity clause of the 1983 Georgia Constitution “follows the preemption rule of previous constitutions by precluding local or special laws when general laws exist on the same subject”). “To violate the constitutional provision, the statute in question must either be a general law which lacks uniform operation throughout the state or a special law for which provision has been made by existing general law.” Lasseter v. Ga. Public Svc. Comm., 253 Ga. 227 (2) (319 SE2d 824) (1984).

A “special law” is one which “affects a limited area or class.” Lasseter, 253 Ga. at 229 (2). While the state constitution does not prohibit special laws per se, the legislature cannot enact special laws affecting special classes “if it has previously legislated in that area by general law nor may it do so if the classification of those affected is unreasonable.” Id. In the case at bar, the 2005 legislation affects a limited class of heath care providers, with that limited class defined by what health care they provide and where they provide it: the limited class consists of those physicians and health-care providers who provide emergency medical care in a hospital’s emergency department, in a hospital’s obstetrical unit, or in a surgical suite immediately following the patient’s evaluation or treatment in a hospital emergency department. Those within the limited class are protected from liability by a lower standard of care and a higher burden of proof — they cannot be found liable for the care they provide unless it is established by clear and convincing evidence that they were grossly negligent.

In Celotex Corp. v. St. Joseph Hosp., 259 Ga. 108 (376 SE2d 880) (1989), this Court found OCGA § 9-3-30.1 to be an unconstitutional special law. That statute extended or revived asbestos-related claims against manufacturers or suppliers otherwise constrained by the existing statute of limitation. The Court described OCGA § 9-3-30.1 as “deal[ing] with a limited activity in a specific industry during a limited time frame. . . .” Id. at 110. The “limited activity in a specific industry” was the manufacturing and supplying of material containing asbestos for the use in buildings, one limited situation within the entire hazardous chemical industry. Id. In the case before us, the limited activity OCGA § 51-1-29.5 (c) covers is the provision of medical emergency care after a patient has arrived in a hospital’s emergency department or obstetrical unit, one limited situation within the scope of the entire health care industry.1 Thus, *15OCGA § 51-1-29.5 (c) is a special law and is subject to constitutional limitations as such.

The majority’s reliance on Terrell County v. Albany/Dougherty Hosp. Auth., 256 Ga. 627 (352 SE2d 378) (1987), for the proposition that the standard of care provision was upheld as a general law is misplaced. In that case, in which the Albany/Dougherty County Hospital Authority sought payment from Terrell County for services rendered to indigent pregnant residents of Terrell County, Terrell County challenged the constitutionality of certain statutory provisions, OCGA §§ 31-8-42 and 31-8-43 (c), which “involve[ ] the county’s obligation to pay for services extended to its indigent pregnant residents by a hospital in another county.” Id. These provisions are part of the Hospital Care for Pregnant Women Act (OCGA § 31-8-40 et seq.), which also includes a provision that requires a showing of gross negligence before a physician, nurse, medical assistant or a hospital or any of its agents or employees can be found civilly liable for malpractice in connection with treatment afforded indigent pregnant women in labor. OCGA § 31-8-44. In its holding, the Terrell County court stated: “An attack on OCGA § 31-8-40 et seq., as special legislation also fails.” Terrell County, 256 Ga. at 630 (emphasis supplied).

The majority in this case, due to the Terrell County court’s use of the abbreviation “et seq.,” concludes that, although the gross negligence standard of care found in OCGA § 31-8-44 was not specifically attacked in Terrell County, “that provision was enacted as part of the legislation that was expressly found not to be a special law.” Maj. Op. at 9. There is no doubt that the Terrell County court’s use of the term “et seq.” is confusing and misleading. However, one plain, simple fact remains: The Terrell County court did not hold — nor could it have held — that OCGA § 31-8-44 is a general law because Terrell County did not have standing to raise such an attack. Standing is a “ ‘prerequisite to attacking the constitutionality of a statute.’ ” Perdue v. Lake, 282 Ga. 348, 348 (647 SE2d 6) (2007). A litigant has standing “only if that law has an adverse impact on that litigant’s own rights.” In the Interest of A. C., 285 Ga. 829, 832 (1) (686 SE2d 635) (2009). OCGA § 31-8-44 did not adversely affect Terrell County’s rights — the Terrell County record is devoid of any reference to medical malpractice or harm to any patient at all. It is impossible for anyone, let alone a county, to allege harm under *16OCGA § 31-8-44, a statute that lowers the standard of care in certain medical malpractice cases, without attempting to show some form of malpractice or patient injury in the first place.

Furthermore, an attack on OCGA § 31-8-44 was not raised and ruled upon at the trial court in Terrell County. “[T]his court will never pass upon the constitutionality of an act of the General Assembly unless it clearly appears in the record that the point was directly and properly made in the court below and distinctly passed on by the trial judge.” Calhoun v. State, 211 Ga. 112, 113 (84 SE2d 198) (1954). In its answer to the Albany/Dougherty Hospital Authority’s complaint seeking payment for treatment afforded indigent pregnant Terrell County residents in labor, Terrell County raised two specific attacks on the constitutionality of “OCGA § 31-8-40 et seq.” under Art. Ill, Sec. VI, Par. IV of the Georgia Constitution of 1983 that exclusively addressed the issue of reimbursement obligations. Terrell County then made one general attack on the entire Hospital Care for Pregnant Women Act: “O.C.G.A. Section 31-8-40 et seq. is unconstitutional ... in that it is a law of a general nature which fails to operate uniformly throughout the whole State upon the subject or class of subjects with which it proposes to deal.” The language of the attack, taken straight from Lasseter, supra, merely makes the claim that the whole Act is not a general law. The defendant did not raise a specific attack on the standard of care provision in the Act. This court cannot consider such “vague and indefinite attacks” on the constitutionality of a legislative act. Dade County v. State of Ga., 201 Ga. 241, 245 (39 SE2d 473) (1946). No doubt due to Terrell County’s failure to raise any attack on the standard of care provision as a special law, the Terrell County trial court merely ruled on the issue of the uniformity of the economic impact on counties. Thus, no constitutional attack on the standard of care provision in OCGA § 31-8-44 was raised and ruled upon in the Terrell County trial court. Therefore, Terrell County is inapposite and provides no support for the majority’s holding.

2. Because OCGA § 51-1-29.5 (c) is a special law, the Georgia Constitution of 1983 requires compliance with specific constitutional limitations. One such constitutional limitation on a special law is the existence of a general law on the same subject. The uniformity clause of the Georgia Constitution of 1983 precludes the enactment of special legislation when “a general law exists on the same subject.” Fieldale Farms, supra, 270 Ga. at 275. Preclusion “may be express or implied.” Id. This constitutional special law prohibition is not limited “to those fields and subjects which have been completely exhausted by a general law. It embraces every field and subject which has been covered, though superficially, by a general law.” Hudgins, supra, 193 Ga. at 623. Here, the General Assembly has already *17enacted OCGA § 51-1-27, a general law which states the standard of care in medical malpractice cases to be “reasonable care.” Because OCGA § 51-1-29.5 (c) is a special law that regulates the same subject matter as OCGA § 51-1-27, it is unconstitutional under the Georgia Constitution of 1983.

3. Even if there were no general law on point, OCGA § 51-1-29.5 (c) is an unconstitutional special law for its application of an unreasonable and arbitrary classification. In Celotex Corp., supra, 259 Ga. 108, this Court struck down as an unconstitutional special law the statute which revived or extended the period of limitation within which a suit against asbestos manufacturers and suppliers could be sued because it singled out, through unreasonable classification, claims against asbestos manufacturers and suppliers from all other claims based on similar toxic substances. Id. at 110.

Here, the question is whether OCGA § 51-1-29.5 (c) is unreasonable or arbitrary in its classification. In determining whether the legislature’s classification is unreasonable, we compare the statutory classification to the legislative purpose of the enactment. See State v. Martin, 266 Ga. 244, 246 (466 SE2d 216) (1996). In enacting OCGA § 51-1-29.5 (c), the General Assembly found

that there presently exists a crisis affecting the provision and quality of health care services in this state. Hospitals and other health care providers in this state are having increasing difficulty in locating liability insurance and, when such hospitals and providers are able to locate such insurance, the insurance is extremely costly. The result of this crisis is the potential for a diminution of the availability of access to health care services and a resulting adverse impact on the health and well-being of the citizens of this state.

Ga. L. 2005, p. 1, § 1 (emphasis supplied). The General Assembly found that all health care providers, not merely those who treat patients after they arrive in hospital emergency rooms or obstetrical units, are incurring difficulty in locating affordable liability insurance. Similarly, all health care providers of emergency medical care, regardless of the location at which such care is provided, are incurring difficulty in locating affordable liability insurance. The General Assembly’s effort to assist health care providers is arbitrary in that an emergency medical technician treating a patient who suffered a heart attack in an ambulance on the way to the emergency room does not receive the benefits of the statute simply because the patient has not yet arrived at the emergency room. The classification is unreasonable in that a physician who treats a patient for an *18emergency medical condition in an emergency room receives the statute’s additional protection while a physician who treats the same condition in his office or on a house call does not. Because OCGA § 51-1-29.5 (c) contains an unreasonable and arbitrary classification, it is an unconstitutional special law.

Decided March 15, 2010 Reconsideration denied April 8, 2010. Oates & Courville, Samuel W. Oates, Jr., Traci G. Courville, Bondurant, Mixson & Elmore, Michael B. Terry, Nicole G. Iannarone, Kamal Ghali, for appellants. Hall, Booth, Smith & Slover, Roger S. Sumrall, Carlock, Copeland & Stair, Wade K. Copeland, Ashley E. Sexton, for appellees. Alston & Bird, Angela T. Burnette, Donna B Bergeson, Owen, Gleaton, Egan, Jones & Sweeney, H. Andrew Owen, Jr., Jonathan C. Lippert, Amy J. Kolczak, amici curiae.

For the aforementioned reasons, I respectfully dissent from the majority’s decision to uphold OCGA § 51-1-29.5 (c) against the challenge that it is an unconstitutional special law.

I am authorized to state that Chief Justice Hunstein and Justice Thompson join this opinion.

Although OCGA § 51-1-29.5 (c) does not contain a “limited time frame,” as mentioned *15in Celotex Corp. and Lasseter, that phrase was used in both cases to describe the statute at issue as having a limited time frame. There is no requirement that a finite temporal application period exist in a statute to consider it affecting “a limited area or class,” the definition of a special law. See Lasseter, 253 Ga. at 229. OCGA § 51-1-29.5 (c) is a special law because it “affects a limited area or class.”