Supreme Court of the United States · Official docket →
Sandra J. Bezanson, as Executor of the Estate of Dennis G. Bezanson v. Exeter Hospital, Inc.
Paid petition · Supreme Court of New Hampshire, No. 2024-0599 · judgment October 28, 2025
Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.
Questions presented
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Whether the Due Process Clause of the Fourteenth Amendment permits a state supreme court to forfeit a litigant’s rights based on an administrative failure in the court’s mandatory electronic filing system— where the court’s own secure portal shows a timely “Submitted” filing—followed by a refusal to correct the error upon presentation of the system-generated proof.
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Whether a state trial court violates procedural due process by imposing the “death penalty” sanction of dismissal for asserted discovery deficiencies where the court and opposing party refused meaningful conferral and the court denied the Petitioner’s motion seeking the conference required by the court’s own case-structuring and discovery framework, thereby creating a procedural trap and foreclosing compliance.
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Whether due process is violated where later-issued federal agency determinations (Department of Veterans Affairs / Board of Veterans’ Appeals) confirm that critical non-VA community-care medical records were missing due to third-party provider transmission failures under federal community-care obligations—evidence that did not exist during the state discovery period—and the state courts nonetheless treated resulting record gaps as willful “discovery abuse” warranting dismissal.
Counsel of record
For petitioner
Sandra Bezanson
For respondent
Jonathan A. Lax
Gallagher Callahan & Gartrell, P.C.
Case
Conference history
Distributed for 1 conference
Proceedings
- Mar 30 2026Petition DENIED.
- Mar 11 2026DISTRIBUTED for Conference of 3/27/2026.
- Feb 04 2026Waiver of right of respondents Exeter Hospital, Inc. and Exeter Health Resources, Inc. to respond filed.
- Jan 26 2026Petition for a writ of certiorari filed. (Response due March 4, 2026)