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Sandhills Medical Foundation, Inc. v. Joann Ford, et al.

Paid petition · United States Court of Appeals for the Fourth Circuit, No. 22-2268 · judgment March 29, 2024


Certiorari denied · March 3, 2025
Pre-decision estimate: 3% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Question presented

42 U.S.C. § 233(a) provides Public Health Service officers and employees—and those deemed equivalent via § 233(g)—comprehensive immunity from suit by making the Federal Tort Claims Act a plaintiff’s exclusive remedy in “any . . . civil action or proceeding . . . resulting from the performance of medical, surgical, dental, or related functions” undertaken within their scope of employment. The question presented is: Does “related functions” in 42 U.S.C. § 233(a)’s recitation of immunized conduct mean functions related to medical, surgical, or dental functions—as the Ninth Circuit concluded in Friedenberg v. Lane County, 68 F.4th 1113 (9th Cir. 2023)—or, as the Fourth Circuit concluded, mean activity in “a field of health care outside of medicine, surgery, or dentistry,” App. 18a, such that § 233(a) immunizes only the “performance of the provision of health care.” App. 20a.

Counsel of record

For petitioner
Matthew S. Freedus
Feldesman Leifer LLP

For respondent
Sarah M. Harris
Acting Solicitor General

Case

Conference history
Distributed for 1 conference

Amicus briefs
1 cert-stage

Linked docket
24A104

Proceedings

  1. Mar 03 2025
    Petition DENIED.
  2. Feb 12 2025
    DISTRIBUTED for Conference of 2/28/2025.
  3. Feb 11 2025
    Reply of petitioner Sandhills Medical Foundation, Inc. filed. (Distributed)
  4. Jan 29 2025
    Brief of respondent United States in opposition filed.
  5. Dec 30 2024
    Motion to extend the time to file a response is granted and the time is further extended to and including January 29, 2025, for all respondents.
  6. Dec 30 2024
    Brief of respondents Joann Ford, et al. in opposition filed.
  7. Dec 27 2024
    Motion to extend the time to file a response from December 30, 2024 to January 29, 2025, submitted to The Clerk.
  8. Nov 26 2024
    Brief amici curiae of Professor Sara Rosenbaum, et al. filed.
  9. Nov 13 2024
    Motion to extend the time to file a response is granted and the time is extended to and including December 30, 2024, for all respondents.
  10. Nov 12 2024
    Motion of respondent Joann Ford to extend the time to file a response from November 29, 2024 to December 30, 2024, submitted to The Clerk.
  11. Nov 01 2024
    Motion to extend the time to file a response is granted and the time is extended to and including December 30, 2024.
  12. Oct 31 2024
    Motion of the Solicitor General to extend the time to file a response from November 29, 2024 to December 30, 2024, submitted to The Clerk.
  13. Oct 25 2024
    Petition for a writ of certiorari filed. (Response due November 29, 2024)
  14. Aug 06 2024
    Application (24A104) granted by The Chief Justice extending the time to file until October 25, 2024.
  15. Jul 25 2024
    Application (24A104) to extend the time to file a petition for a writ of certiorari from August 26, 2024 to October 25, 2024, submitted to The Chief Justice.