Means v. United States Conference of Catholic Bishops

Mercy Health Partners is a Catholic hospital in Michigan under the supervision of Catholic Health Ministries (CHM) (defendant). CHM required Mercy to follow ethical and religious directives published by the United States Conference of Catholic Bishops (USCCB). On December 1, 2020, Tamesha Means (plaintiff) went into labor when she was 18 weeks pregnant and sought treatment at Mercy. The doctors discovered the fetus still had a heartbeat, but the amniotic sac had ruptured, a condition that endangers the mother’s health and typically leads to stillbirth. However, the doctors did not share that information with Means or offer Means an abortion or any treatment that would complete the miscarriage. Instead, the doctors sent Means home with some pain medication. Means returned the following morning with pain and bleeding, but Mercy sent her home after Means’s fever subsided. That night, Means returned and delivered her baby, who died soon after. Two years later, a public health worker learned about Means’s ordeal and talked to Mercy’s vice president. The vice president stated that the USCCB ethical directives prohibited Mercy from inducing labor or offering an abortion in Means’s case. The statute of limitations barred Means from suing Mercy for malpractice. Therefore, Means sued USCCB and CHM for negligence, alleging that the directives caused Mercy to withhold information about the risks of Means’s condition and treatment options. Means asserted that she suffered physical, psychological, and emotional pain. After dismissing the claim against USCCB for lack of personal jurisdiction, the district court dismissed the claim against CHM for failure to state a claim. Means appealed to the United States Court of Appeals for the Sixth Circuit.