Ogunde v. Prison Health Services, Inc.

Present:   All the Justices

OLUDARE OGUNDE

v.   Record No. 061121      OPINION BY JUSTICE ELIZABETH B. LACY
                                         June 8, 2007
PRISON HEALTH SERVICES,
INC., ET AL.

           FROM THE CIRCUIT COURT OF GREENSVILLE COUNTY
                     Samuel E. Campbell, Judge

      Prison Health Services, Inc. (PHS) provides medical

services to persons incarcerated at certain state correctional

centers, including Greensville Correctional Center, pursuant

to a contract with the Virginia Department of Corrections

(VDOC).    In 2005, Oludare Ogunde was an inmate at Greensville

Correctional Center.     Acting pro se, Ogunde filed a motion for

judgment against PHS and its employees Katie M. Hamlin,

Benjamin Ellis, Joan Hill, RN, and Doctors Amjad Mughal and

Nagash Tesemma (the Employees or the PHS Employees).1     In his

complaint, Ogunde alleged that he suffered from a skin

condition diagnosed as "severe acne cysts and acne

keloidalis," and that this condition was aggravated by

shaving.    According to the complaint, PHS and the Employees

denied Ogunde proper medical treatment for his skin condition




      1
       Ogunde also brought a claim against a "Dr. Stephens."
Dr. Stephens was never served and is not a party to this
appeal.
and failed to issue him an exemption from VDOC's inmate

grooming policy.2

     Ogunde's complaint identified seven claims for relief

against PHS and the Employees:    negligence or gross

negligence; intentional infliction of emotional distress;

medical malpractice; breach of contract; cruel and unusual

punishment in violation of Section 9, Article I of the

Constitution of Virginia; and a violation of his

constitutional rights under the Eighth Amendment of the United

States Constitution.   Ogunde sought, inter alia, compensatory

damages and an injunction requiring PHS and the Employees to

provide him medical treatment and to issue him an exemption

from the inmate grooming policy.

     The trial court dismissed Ogunde's negligence, gross

negligence and medical malpractice claims, finding that PHS

and the Employees were employees or agents of the

Commonwealth, not independent contractors, and as such were

entitled to sovereign immunity.       The trial court also

dismissed the breach of contract claim finding that there was


     2
       VDOC's Operating Procedure prohibits male inmates from
wearing goatees or beards. It provides, however, that if an
inmate "has a medical condition that is aggravated by shaving
or complete removal of facial hair, the offender must receive
a 'no shave' medical order from the institutional medical
authority. Offenders who have a 'no shave' medical order must
continually trim all facial hair to not exceed 1/4" in
length."

                                  2
no privity; sustained PHS's and the Employees' demurrer to the

intentional infliction of emotional distress cause of action;

and dismissed Ogunde's state and federal constitutional

claims.   In addition, the trial court denied Ogunde's motions

to amend his motion for judgment and to add the Commonwealth

and another PHS physician as party defendants.   We awarded

Ogunde an appeal and, for the reasons stated below, we will

affirm in part and reverse in part the judgment of the trial

court and remand the case for further proceedings.

                      I.    DISMISSED CLAIMS

                     A.    Medical Malpractice

     We begin by reviewing the trial court's dismissal of

Ogunde's claims of medical malpractice based on its

determination that PHS and the Employees were entitled to

sovereign immunity because they were not independent

contractors.3

     In Epperson v. DeJarnette, 164 Va. 482, 486, 180 S.E.

412, 413 (1935), we defined the term "independent contractor"

as

     a person who is employed to do a piece of work without
     restriction as to the means to be employed, and who
     employs his own labor and undertakes to do the work
     according to his own ideas, or in accordance with plans

     3
       The trial court concluded that Ogunde's claims of
negligence were in fact medical malpractice claims, and thus
limited Ogunde's negligence claim to "medical negligence."
Ogunde has not appealed this determination.

                                  3
     furnished by the person for whom the work is done, to
     whom the owner looks only for results.

If a person meets this definition, an independent contractor

relationship exists and sovereign immunity is unavailable.

Atkinson v. Sachno, 261 Va. 278, 283-84, 541 S.E.2d 902, 904-

05 (2001).

     We have previously recognized "that there are abundant

tests and criteria that can be used to determine whether the

relationship between the individual and the Commonwealth is

that of an independent contractor or an employee."      Id. at

284, 541 S.E.2d at 905.   In each case, however, "the

individual circumstances . . . play an important part in

answering the query."   The Texas Co. v. Zeigler, 177 Va. 557,

566, 14 S.E.2d 704, 707 (1941).       In determining whether

physicians are employees or independent contractors, we have

included the following four factors:      (1) selection and

engagement; (2) payment of compensation; (3) power of

dismissal; and (4) power to control the individual's work.

See, e.g., Atkinson, 261 Va. at 284-85, 541 S.E.2d at 905;

Hadeed v. Medic-24, Ltd., 237 Va. 277, 288, 377 S.E.2d 589,

594-95 (1989); Naccash v. Burger, 223 Va. 406, 418-19, 290

S.E.2d 825, 832 (1982).   Although all these factors are

relevant, the fourth factor, "the power of control" is

determinative.   Atkinson, 261 Va. at 284-85, 541 S.E.2d at



                                  4
905; Naccash, 223 Va. at 418-19, 290 S.E.2d at 832.     We apply

this analysis to the facts of this case.4

     PHS and the Employees provided medical services to Ogunde

and other Greensville inmates pursuant to a contract with

VDOC.5   The contract required PHS to "provide all medical,

dental, and mental health services" at several Virginia

correctional centers including Greensville.   PHS was to render

these services in accordance with certain policies set forth

by VDOC, including the inmate grooming policy.   PHS and the

Employees argue the trial court correctly held that they were

not independent contractors under Atkinson, because the

contract did not allow them to control the "means and methods

used . . . to exercise [their] required professional skill and

judgment."   Atkinson, 261 Va. at 283, 541 S.E.2d at 904.

Specifically, PHS and the Employees rely on provisions of the

contract that they contend allow VDOC to pre-approve all

personnel employed or subcontracted by PHS to deliver care,

and require PHS to remove any of its employees with whom VDOC

is dissatisfied if attempts to reach a resolution are

     4
       The PHS and the Employees agree that they are not
employees of VDOC but maintain that they are VDOC's agents.
We make no distinction between employees and agents in the
application of this test to determine independent contractor
status.
     5
       At oral argument, Ogunde abandoned his argument that the
trial court inappropriately relied on the contract, and agreed



                                5
unsuccessful.    They also argue that the contract specifies the

"circumstances and conditions under which PHS may authorize

overtime hours for its employees [and] dictates the number of

personnel that must be employed to prevent shortages," and

sets forth where inmates may be hospitalized for inpatient

care, the methods of delivering off-site medical care, and

where PHS must purchase medications and the medications to be

prescribed for certain illnesses.

     Many of the contract provisions which PHS and the

Employees recite relate to issues of security attaching to

penal institutions, not to the provision of medical services.

The pre-approval of PHS's employees, for example, involves

clearance from VDOC based on a background investigation

including a criminal records check.    Furthermore, in this

context, restrictions such as location for the provision of

medical treatment are not dispositive in resolving the

question whether PHS and the Employees are independent

contractors.    The provisions cited for restricting the

medications that can be prescribed are in an amendment to the

contract, which sets forth a list of 25 medications for use in

the treatment of HIV/AIDS and Hepatitis C.   This amendment,




the contract is dispositive of whether PHS and the Employees
are independent contractors.

                                 6
however, is not applicable to treatment at Greensville

Correctional Center.

     What is crucial to the independent contractor analysis is

that the contract specifically charges PHS with supervising

the work of its own employees and any subcontractors:

     The Contractor [PHS] shall be responsible for
     completely supervising and directing the work under
     this contract and all subcontractors that he may
     utilize, using his best skill and attention.
     Subcontractors who perform work under this contract
     shall be responsible to the prime Contractor. The
     Contractor agrees that he is as fully responsible
     for the acts and omissions of his subcontractors
     and of persons employed by them as he is for the
     acts and omissions of his own employees.

Thus, as set forth in this provision, the actual work to be

performed under the contract – the rendering of medical

services to inmates – remains under the control of PHS.    The

contract provisions related to staffing cited by PHS and the

Employees do not undermine this control.   For instance,

although the contract sets forth staffing requirements, PHS

has the responsibility to "manage its workforce so that there

is sufficient staffing on each and every shift at each

institution in order to assure the delivery of both routine

and emergency health care services to all inmates at all

times."   In short, PHS supervises and directs its employees,

not VDOC.




                                7
     The contract to provide medical services was executed in

response to VDOC's request for proposals under the Virginia

Public Procurement Act, and was the result of a competitive

bidding process.   Based on that fact and on our review of the

contract, we hold that PHS and the Employees are independent

contractors.   Therefore the trial court erred in concluding

that PHS and the Employees were entitled to sovereign

immunity.   Accordingly, we will reverse that portion of the

trial court's judgment dismissing Ogunde's medical malpractice

claims on this basis.6

                     B.   Breach of Contract

     Ogunde also assigns error to the trial court's dismissal

of his breach of contract claim because he was not in privity

with PHS.   Ogunde argues that he is an intended third party

beneficiary of the contract between PHS and VDOC and, as such,

entitled to sue for breach of the contract.

     It is well established that "under certain circumstances,

a party may sue to enforce the terms of a contract even though

he is not a party to the contract."   Levine v. Selective Ins.


     6
       Ogunde also assigns error to the trial court's dismissal
of his gross negligence claim, which was apparently dismissed
as a result of the trial court's determination that PHS and
the Employees were entitled to sovereign immunity. Reversal
of that holding and reinstatement of the medical malpractice
claim necessarily reinstates Ogunde's claim of gross
negligence and we therefore need not address Ogunde's
assignment of error on this issue.

                                8
Co. of Am., 250 Va. 282, 285, 462 S.E.2d 81, 83 (1995); Code

§ 55-22.   "The essence of a third-party beneficiary's claim is

that others have agreed between themselves to bestow a benefit

upon the third party but one of the parties to the agreement

fails to uphold his portion of the bargain."    Copenhaver v.

Rogers, 238 Va. 361, 367, 384 S.E.2d 593, 596 (1989).    In

accordance with this principle, we have allowed third parties

to sue on contracts where "the third party . . . show[s] that

the parties to the contract clearly and definitely intended it

to confer a benefit upon him."    Ward v. Ernst & Young, 246 Va.

317, 330, 435 S.E.2d 628, 634 (1993) (quoting Professional

Realty Corp. v. Bender, 216 Va. 737, 739, 222 S.E.2d 810, 812

(1976)).

     The contract between PHS and VDOC states that its purpose

is to "provide cost effective, quality inmate health care

services for up to approximately 6,000 inmates (initially)

housed at four correctional center facilities," including

Greensville.     The contract then sets forth the scope of health

care services to be provided to the inmates.    Ogunde is one of

these inmates and PHS's performance under the contract renders

a direct benefit to Ogunde.    The contract thus "clearly and

definitely" indicates that PHS and VDOC intended to provide a

benefit to, among others, Ogunde.     Bender, 216 Va. at 739, 222

S.E.2d at 812.


                                  9
     PHS and the Employees argue that Ogunde is not an

intended beneficiary but merely an "incidental" beneficiary of

the contract because if he ceases to be an inmate at

Greensville, the contract, and the duties imposed on PHS, will

remain intact.   As an incidental beneficiary, Ogunde does not

have standing to enforce the contract according to PHS and the

Employees.

     We disagree with the proposition that Ogunde is an

incidental beneficiary.   The status of an intended third party

beneficiary does not depend upon permanent membership in the

class of persons entitled to receive the benefit of the

contract.    In Moorman v. Nationwide Mut. Ins. Co., 207 Va.

244, 148 S.E.2d 874 (1966), we held that a person injured

while riding as a passenger in a motor vehicle was entitled to

recover pursuant to an insurance policy held by the owner of

the vehicle, which obligated the insurer to pay for medical

expenses incurred by any person "while occupying" the insured

vehicle.    We reasoned that the insurance policy had the effect

of placing the injured person "in the position of a third

party beneficiary, and as such, [the injured person] has in

Virginia a statutory right to maintain an action on the

contract in his own name."   Id. at 248, 148 S.E.2d at 877.    We

reached this conclusion despite the fact that once the injured

person was no longer a passenger in the vehicle, she ceased to


                                10
be a member of the class of persons who would benefit from the

contract, which would remain in force, subject to its other

provisions.   Accord Owens v. Haas, 601 F.2d 1242, 1250-51 (2d

Cir.), cert. denied, 444 U.S. 980 (1979) (reversing dismissal

of inmate's breach of contract claim because contract between

prison and the county to provide transportation of prisoners

"indicates that Owens, as a federal prisoner, was intended to

benefit from the agreement").

     Accordingly, we hold that Ogunde was a third party

beneficiary of the contract between PHS and VDOC and the trial

court erred by dismissing Ogunde's breach of contract claim.

                 C.   State Constitutional Claim

     Ogunde alleged that the failure to provide appropriate

medical treatment was cruel and unusual punishment in

violation of Art. I, § 9 of the Constitution of Virginia.    In

response to this claim, PHS and the Employees originally

asserted that the claim was barred by the doctrines of res

judicata and collateral estoppel.    PHS and the Employees

subsequently withdrew their objections on these grounds.     The

dismissal order does not recite the basis for dismissal of the

constitutional claim.

     On appeal, PHS and the Employees argue that the trial

court was justified in dismissing Ogunde's constitutional claim

because Ogunde failed to comply with the Virginia Prisoner


                                11
Litigation Reform Act (VPLRA), Code §§ 8.01-689, et seq.   PHS

and the Employees assert that Code § 8.01-694 of the VPLRA

requires a prisoner to submit documentation or affidavits to

support his claim, and that failure to do so allows the trial

court to dismiss the pleading sua sponte.

     Code § 8.01-694 does not require dismissal of a

prisoner's claim if the prisoner has not attached all

supporting documentation to the complaint.   Rather, the

provision simply describes circumstances which "may" result in

the dismissal of the claim.   Nothing in the VPLRA changes the

rules governing pleadings and motions in Virginia.   The Act

does not require the filing of additional documentation or

affidavits with a pleading.   Regardless whether a trial court

believes a claim brought by a pro se prisoner may ultimately

fail, at the pleading stage the trial court is bound by the

same procedures, rules and policies which apply to a party

represented by counsel.   The VPLRA does not provide courts or

defendants with a mechanism to disregard these procedures in a

suit brought by a pro se prisoner, and we reject the

application of the Act suggested by PHS and the Employees.     In

this case, there is nothing in the record to support the

dismissal of Ogunde's constitutional claim at the pleading

stage, and we accordingly reverse that portion of the trial

court's judgment.


                               12
          D.   Intentional Infliction of Emotional Distress

     Ogunde challenges the trial court's action sustaining

PHS's and the Employees' demurrer to his claim of intentional

infliction of emotional distress.       A demurrer tests the legal

sufficiency of the facts alleged in the plaintiff's complaint.

Sanchez v. Medicorp Health Sys., 270 Va. 299, 303, 618 S.E.2d

331, 333 (2005).     In reviewing a demurrer, a trial court must

consider the pleadings in the light most favorable to the

plaintiff and sustain the demurrer if it is clear that the

plaintiff has not stated a valid cause of action.       Id.   To

survive a demurrer as to the instant claim, a plaintiff must

allege:    "1) the wrongdoer's conduct was intentional or

reckless; 2) the conduct was outrageous or intolerable; 3)

there was a causal connection between the wrongdoer's conduct

and the resulting emotional distress; and 4) the resulting

emotional distress was severe."        Almy v. Grisham, 273 Va. 68,

77, 639 S.E.2d 182, 186 (2007).

     Ogunde alleged in his complaint that PHS and the

Employees denied him treatment and refused to recommend he be

exempted from the grooming policy because they believed the

importance of Ogunde's compliance with the grooming policy

outweighed any medical need for an exemption and because they

erroneously believed "they lack[ed] authority to make such a

recommendation."     Assuming the truth of the allegations, the


                                  13
conduct is not so intolerable or outrageous such that it

"offends against the generally accepted standards of decency

and morality."   Jordan v. Shands, 255 Va. 492, 498, 500 S.E.2d

215, 219 (1998)(quoting Womack v. Eldridge, 215 Va. 338, 342,

210 S.E.2d 145, 148 (1974)).   And, while Ogunde did allege

that their conduct was both intentional and reckless, we are

not bound to accept conclusory allegations in a review of a

demurrer to an intentional infliction of emotional distress

claim.    Id. at 499, 500 S.E.2d at 219 (plaintiff failed to

plead cause of action for emotional distress where her

allegations were "merely conclusional" and did not set forth

any specific conduct by defendants); Russo v. White, 241 Va.

23, 28, 400 S.E.2d 160, 163 (1991)(the court is not "bound by

such conclusory allegations" in considering demurrer to

infliction of emotional distress claim).   Accordingly, we find

no error by the trial court in sustaining the demurrer.

    II.    DENIAL OF MOTIONS TO AMEND AND TO ADD NEW PARTIES

     Following the trial court's ruling sustaining the

demurrer to Ogunde's intentional infliction of emotional

distress claim, dismissing his breach of contract claim, and

consolidating his negligence claims with his medical

malpractice claim, discovery continued and PHS and the

Employees filed their pleas of sovereign immunity.   In

response, Ogunde filed two motions, one to add the


                                14
Commonwealth as a party defendant and a second to amend his

motion for judgment to "cure the imperfections" in his prior

pleading and to add new counts and a claim for punitive

damages.    Ogunde asserted the amendments resulted from matters

arising in discovery and that PHS and the Employees would not

be prejudiced by allowing the proposed amendments.    A copy of

the amended motion for judgment was attached to the motions to

amend.   PHS and the Employees did not file any written

opposition to the proposed amendments.   Following a hearing,

the trial court denied Ogunde's motions, granted the sovereign

immunity plea, and dismissed Ogunde's motion for judgment.

Ogunde has assigned error to the trial court's denial of his

motions to amend.

     Ogunde's stated reason for adding the Commonwealth as a

party and including a claim under the Virginia Tort Claims Act

was in response to PHS's and the Employees' claim of sovereign

immunity.   In light of our holding that PHS and the Employees

are independent contractors and not entitled to sovereign

immunity, these amendments are no longer necessary and we need

not address Ogunde's arguments directed to that part of the

trial court's ruling.

     PHS and the Employees raise a number of arguments in

support of the trial court's exercise of its discretion in

denying the remaining amendments.    They again assert that


                                15
Ogunde did not satisfy the pleading requirements of the VPLRA

because he did not provide "written documentation to support

his claim."   We have already rejected that construction of

Code § 8.01-694 and reject it again here as a basis for

refusing the amendments sought.      PHS and the Employees also

claim that certain counts were barred by the statute of

limitations and that venue was improper.     These arguments may

be defenses to the claims but were not resolved by the trial

court, and thus are not appropriate as a basis for denying the

amendments.

     Whether to grant leave to amend pleadings is a matter

within the sound discretion of the trial court.     Kole v. City

of Chesapeake, 247 Va. 51, 57, 439 S.E.2d 405, 409 (1994).

"Leave to amend shall be liberally granted in furtherance of

the ends of justice."   Rule 1:8.    Ogunde had not previously

sought to amend his motion for judgment and filed this request

in a timely manner, following the relevant rulings of the

trial court and the conclusion of discovery.     Nothing in the

amendments suggests that PHS and the Employees would have been

prejudiced by allowing the amendments.     Under these

circumstances, Ogunde provided good cause to seek to amend his

complaint.    See Ford Motor Co. v. Benitez, 273 Va. 242, 252,

639 S.E.2d 203, 208 (2007); Mortarino v. Consultant Eng'g

Servs., 251 Va. 289, 295-96, 467 S.E.2d 778, 782 (1996).


                                16
Accordingly, we find that the trial court abused its

discretion in failing to allow Ogunde to file his amended

motion for judgment.

                           CONCLUSION

     In sum, we hold that the trial court erred in holding

that PHS and the Employees were entitled to sovereign immunity

and in dismissing Ogunde's medical malpractice and gross

negligence claims on that basis, and in dismissing Ogunde's

claims for breach of contract and violation of Article I, § 9

of the Constitution of Virginia.    We further hold that the

trial court abused its discretion by denying Ogunde leave to

amend his complaint.   We find no error by the trial court in

sustaining the demurrer to Ogunde's claim for intentional

infliction of emotional distress.

     For these reasons, we will affirm in part and reverse in

part the circuit court's judgment and remand the case for

proceedings not inconsistent with this opinion.

                                                Affirmed in part,
                                                reversed in part,
                                                and remanded.




                               17