Medina v. Lopez-Roman

In March 1994, 15-year-old Christopher Medina (plaintiff) fell on his head at a residential mental-health treatment center in Texas. Medina was taken to the emergency room, where he was treated by Dr. H. Lopez-Roman (defendant). Medina complained of dizziness, neck pain, and an inability to move his arms. After discussing Medina’s mental-health history with Medina’s psychiatrist, Dr. Stuart Crane (defendant), Dr. Lopez-Roman concluded that Medina was experiencing psychosomatic symptoms. Dr. Lopez-Roman discharged Medina from the emergency room. The following day, after Medina was still complaining of pain, he was taken to a different hospital and diagnosed with a broken neck. Medina underwent surgery to fuse his vertebrae and started physical rehabilitation. Medina turned 18 on April 3, 1996. After sending statutorily required presuit notices to both Dr. Crane and Dr. Lopez-Roman, Medina brought an action against both doctors on April 3, 1998, asserting claims including medical malpractice. The doctors moved for summary judgment, arguing that Texas’s two-year statute of limitations for healthcare-liability actions had expired before Medina filed suit. The doctors agreed that because Medina was a minor when the alleged medical malpractice occurred, the statute of limitations was tolled until Medina’s eighteenth birthday on April 3, 1996. However, the doctors asserted that the statute of limitations expired at midnight on April 2, 1998, as that date was a “full two years” after the limitations period began to run. The trial court granted the doctors’ summary-judgment motion on Medina’s medical-malpractice claim, and Medina appealed to the Texas Court of Appeals.