## Facts

- Nellie Woods, an Ohio citizen and administratrix of her husband’s estate, sued a Florida hospital, two Florida physicians, and their insurers for wrongful death based on alleged medical malpractice under Florida law.
- Woods filed the action in federal court in the Southern District of Florida based on diversity jurisdiction.
- Florida statutes required malpractice claimants to submit claims to a medical malpractice mediation panel before filing suit.
- Woods did not complete the statutory mediation process before filing.
- Defendants moved to dismiss on the ground that the mediation requirement was a condition precedent to suit.
- The district court dismissed the action for noncompliance, and Woods appealed.

## Issues

1. Whether a federal court sitting in diversity must enforce Florida’s pre-suit medical malpractice mediation requirement as a condition precedent to filing suit.
2. Whether enforcing the mandatory mediation requirement violates the plaintiff’s right to a jury trial.

## Decision

- The Fifth Circuit affirmed the dismissal.
- The court held that Florida’s mediation requirement applies in federal diversity actions asserting Florida medical malpractice and related wrongful death claims.
- The court held the requirement does not violate jury-trial rights because mediation is nonbinding and the parties may demand a jury trial after mediation.
- The court emphasized that mediation panel findings of fact are inadmissible in subsequent court proceedings, leaving the jury as the ultimate factfinder at trial.

## Legal Principles

- In diversity cases, federal courts apply state-law requirements that function as conditions precedent to suit when they are part of the state’s framework governing the asserted state-law claim and no controlling federal rule displaces them.
- A state-mandated, pre-suit mediation process for medical malpractice claims is constitutionally permissible where:
  - the panel’s determination is nonbinding,
  - either party may proceed to court after mediation, and
  - panel factual findings are inadmissible at any later trial.
- A procedure that delays access to trial until completion of a nonbinding pre-suit process does not violate the Seventh Amendment where the jury remains the final adjudicator of disputed facts in any subsequent trial.

## Conclusion

The Fifth Circuit held that Florida’s statutory pre-suit medical malpractice mediation requirement is enforceable in federal diversity litigation as a condition precedent to filing and does not impair the right to a jury trial because the process is nonbinding and does not constrain the jury’s later factfinding.


Woods v. Holy Cross Hosp., 591 F.2d 1164 (5th Cir. 1979)