## Facts

- A mother sued a hospital and an obstetrician in federal court in Puerto Rico, alleging negligent obstetrical care during childbirth caused her daughter’s cerebral palsy.
- During scheduling conferences, the hospital challenged the factual basis for the malpractice allegations and pressed for specific support, including expert evidence on standard of care and causation.
- The hospital moved for judgment on the pleadings under Federal Rule of Civil Procedure 12(c).
- In opposing the motion, the plaintiff submitted an expert report describing the asserted professional basis for negligence and causation.
- The district court considered materials outside the pleadings, converted the Rule 12(c) motion to a Rule 56 summary judgment motion, and entered summary judgment for the hospital.
- The plaintiff appealed, arguing the conversion and resulting procedure were improper.

## Issues

1. When a court considers matters outside the pleadings on a Rule 12(c) motion, must it treat the motion as one for summary judgment under Rule 56?
2. If conversion occurs, did the plaintiff receive adequate notice and a reasonable opportunity to present materials pertinent to summary judgment?
3. Whether any alleged defect in labeling or procedure warranted reversal absent prejudice.

## Decision

- The First Circuit affirmed judgment for the hospital.
- The district court properly converted the Rule 12(c) motion to a Rule 56 motion after considering the plaintiff’s expert report and other non-pleading materials.
- The plaintiff had a reasonable opportunity to present pertinent evidence and was not unfairly surprised by the court’s use of summary judgment procedures.
- Any dispute over the motion’s label was non-prejudicial because the court addressed the matter under the summary judgment framework and the plaintiff responded with evidentiary materials.

## Legal Principles

- If matters outside the pleadings are presented and not excluded on a Rule 12(c) motion, the motion must be treated as one for summary judgment under Rule 56.
- Upon conversion, the nonmoving party must be given notice and a reasonable opportunity to present all material pertinent to summary judgment.
- Courts focus on functional substance rather than captions; reversal generally requires a showing of prejudice from inadequate notice or lack of opportunity to submit evidence.
- Summary judgment is appropriate where the record shows no genuine dispute of material fact and the movant is entitled to judgment as a matter of law.

## Conclusion

The First Circuit upheld summary judgment for the hospital because the district court correctly converted the Rule 12(c) motion to a Rule 56 motion upon considering evidence outside the pleadings, and the plaintiff had sufficient notice and opportunity to submit relevant materials, with no showing of prejudice.


Rubert-Torres v. Hosp. San Pablo, Inc., 205 F.3d 472 (1st Cir. 2000)