Christus Health Gulf Coast (As an Entity, D/B/A Christus St. Catherine Hospital, and Formerly D/B/A Christus St. Joseph Hospital) v. Linda G. Carswell

A hospital’s management of an autopsy is a “professional or administrative service[ ] directly related to health care.” See Tex. Civ. Prao. & Rem.Code Ann. § 74.001(a)(13) (West 2011); CHCA Bayshore, L.P. v. Ramos, 388 S.W.3d 741, 747 (Tex.App.-Houston [1st Dist.] 2012, no pet.) (holding that Chapter 74 governed claim for emotional distress arising from negligence in handling fetal remains). The panel in this case decides that fraud relating to procuring an autopsy is not a health care liability claim, and that the damages the jury awarded for mental anguish associated with this fraud are not…