Kolodecik v. Hospital of Saint Raphael
A hospital that seeks compensation against the decedent's estate for unpaid medical expenses may not be able to allege a special defense of laches against the estate fiduciaries, after they deny the hospital's claim, because laches is an equitable defense, and the hospital requests monetary damages, or an action at law. On Aug. 23, 2009, the plaintiffs' mother, Eleanor Kolodecik, passed away. In October, the Probate Court appointed the plaintiffs as fiduciaries of their mother's estate, and an inventory of the estate's assets was filed. In January 2010, the defendant, the Hospital of Saint Raphael, filed a claim in the amount of $2.5 million, for medical services allegedly provided to the decedent. The plaintiffs apparently permitted and then denied the hospital's claim. In response to the hospital's objection, the Probate Court removed the plaintiffs as fiduciaries, appointed other fiduciaries and reinstated the hospital's claim. The plaintiffs appealed to the Superior Court and asked the court to vacate the Probate Court's decision and to reinstate the plaintiffs as fiduciaries. The hospital filed a special defense, alleging that laches barred the plaintiffs' decision to deny the hospital's claim. The plaintiffs moved to strike the special defense of laches. To prevail on a defense of laches, a party must allege that there was inexcusable delay that resulted in prejudice. The Superior Court found that the laches special defense was legally insufficient, because it failed to allege prejudice as a result of an inexcusable delay. Even if the hospital's special defense had alleged prejudice, laches is an equitable defense, and the hospital requests monetary damages for unpaid medical expenses, which is an action at law. The court granted the plaintiffs' motion to strike.