Burke v. Snyder

Appellant, Susan Burke, challenges the dismissal of her fourth amended complaint filed against Dr. Arthur Snyder for injuries she allegedly sustained during a medical examination. The trial court entered the order of dismissal because Burke failed to attend a case management hearing. Because the trial court did not make explicit findings in the order of dismissal of willful noncompliance or deliberate disregard of the order to attend the case management hearing, we must reverse and remand for further proceedings. The cases uniformly hold that an order imposing the severe sanction of dismissal…