Memorial Healthcare Group, Inc. v. Vickers, [A25A0978, Nov. 3, 2025; reconsideration denied Nov. 17, 2025] __ S.E.2d __ (Ga. Ct. App. 2025).
The court (Doyle, P.J.; Markle and Padgett, JJ., concur) vacated and remanded with direction.
Plaintiff sued a Florida hospital for malpractice related to the decedent’s care following a car accident. Vacating and remanding, and applying the long-arm statute, the court concluded that the alleged contacts did not support personal jurisdiction. The contacts consisted of telephone communications with a Georgia family member, bills mailed to Georgia, and a letter responding to a complaint. These limited contacts did not amount to the “regular,” “persistent,” or “substantial” activity necessary to establish jurisdiction.. Ms.**14–15.
The court further held that allegations concerning broader HCA corporate activity, including operations of other hospitals in Georgia or marketing in multistate regions, could not be imputed to the Florida hospital for purposes of personal jurisdiction. Ms.**15–16. As the complaint’s allegations did not establish statutory or minimum constitutional contacts, the trial court erred in denying the motion to dismiss.