## Facts

- Tamesha Means, at about eighteen weeks’ gestation, went to Mercy Health Partners, a Catholic hospital in western Michigan, after premature labor symptoms.
- She was diagnosed with preterm premature rupture of membranes (PPROM) and later alleged she was not accurately informed of risks, not properly diagnosed/treated for infection, and not offered induction or abortion despite asserted non-viability and risk to her health.
- Means was discharged, returned twice with worsening symptoms, and ultimately delivered a baby who died shortly after birth.
- Means alleged the hospital’s care was constrained by religious directives for Catholic health care promulgated by the United States Conference of Catholic Bishops (USCCB) and adopted/enforced for the hospital by Catholic Health Ministries (CHM) leadership.
- Means did not sue the hospital or physicians; by the time she learned the asserted role of the directives, she alleged the malpractice limitations period had expired.
- She sued USCCB and three individuals associated with CHM, asserting Michigan state-law negligence based on promulgation, adoption, and enforcement of the directives.

## Issues

1. Whether a federal court in Michigan could exercise specific personal jurisdiction over USCCB based on its promulgation of Catholic health-care directives allegedly followed at a Michigan hospital.
2. Whether the complaint stated a plausible Michigan negligence claim against CHM-related defendants by alleging they owed Means a duty of care arising from adopting and enforcing the directives.

## Decision

- The Sixth Circuit affirmed dismissal of the claims against USCCB for lack of personal jurisdiction.
- The court held USCCB’s promulgation of general directives was insufficient to show purposeful availment of Michigan and was too attenuated from Means’s injury, which depended on independent medical decisions by the hospital and physicians.
- The Sixth Circuit affirmed dismissal of the claims against the CHM defendants under Rule 12(b)(6).
- The court held Michigan negligence law did not recognize a duty owed to Means by upstream actors whose role was adopting/enforcing broad ethical directives, where clinical care remained the responsibility of independent medical professionals.

## Legal Principles

- Specific personal jurisdiction requires purposeful availment of the forum; issuing general guidance not directed to the forum, without ownership, operation, or direct participation in the alleged injury, is insufficient.
- Michigan negligence claims require duty, breach, causation, and damages; duty is a legal question turning on the parties’ relationship and whether the defendant’s conduct created a foreseeable risk of harm.
- Entities or individuals who promulgate or require general ethical/religious directives, without providing medical treatment or making clinical decisions, do not thereby assume a tort duty for harms arising from independent medical judgment of hospitals and physicians.
- Courts generally decline to extend negligence liability to remote policy-setters when the alleged harm depends on intervening decisions by independent professionals and no special relationship exists with the plaintiff.

## Conclusion

The Sixth Circuit concluded Michigan courts lacked personal jurisdiction over USCCB based on promulgating nationwide Catholic health-care directives, and that Michigan negligence law imposed no duty on CHM-related defendants for adopting and enforcing those directives where independent medical actors controlled patient care.


Means v. U.S. Conference of Cath. Bishops, 836 F.3d 643 (6th Cir. 2016)