Montejo v. Martin Memorial Medical Center

Montejo Gaspar Montejo (plaintiff) was appointed the guardian of Luis Alberto Jimenez after Jimenez was in a car crash that left him with brain damage and significant physical injuries. Although Jimenez lived and worked in Florida, he was an undocumented Guatemalan national. Jimenez was initially hospitalized in February 2000 at Martin Memorial Medical Center (the hospital) (defendant). After around 20 months of care at the hospital and a skilled nursing facility, Montejo submitted a guardianship plan stating that 24-hour care would be required for Jimenez for the next year. Because Jimenez was poor, his medical expenses were increasing, and Medicare would not pay for his care, the hospital intervened in the guardianship proceedings, seeking authorization to discharge Jimenez and send him back to Guatemala for continuing care. Federal law required a demonstration that appropriate care could be received in Guatemala. At a hearing in June 2023, a circuit court granted the hospital permission to send Jimenez to Guatemala. Montejo moved for rehearing, which was denied on July 9. On that same day, Montejo filed an appeal and moved to stay the court’s order allowing Jimenez’s discharge until the appeal was heard. The circuit court instructed the hospital to respond to Montejo’s motion to stay by 10:00 a.m. on July 10. Instead, the hospital discharged Jimenez, carried him to an airport in an ambulance, and flew him to Guatemala on a private plane. In May 2004, the Florida District Court of Appeal reversed the circuit court’s order that had authorized Jimenez’s return to Guatemala because there was not enough evidence that the medical care Jimenez needed was available in Guatemala and because the circuit court did not have subject-matter jurisdiction to have permitted Jimenez’s deportation. Thus, in September 2004, Montejo sued the hospital for false imprisonment because of Jimenez’s confinement in the ambulance and the airplane. The hospital moved for dismissal or judgment on the pleadings, arguing in part that Montejo could not show the fourth element of a false-imprisonment claim relating to the unreasonableness of detention because the hospital was acting pursuant to a court order that was valid at the time. The circuit court dismissed Montejo’s claim with prejudice. Montejo appealed.