Health Management Associates, Inc. v. Weiner

Dr. Roger Weiner brought a malicious-prosecution claim against Health Management Associates Inc. and Teena Rowe. Weiner was prosecuted in federal district court for violating the Mann Act; he sought dismissal of the charges, alleging that the interstate-commerce element was not met. The district court dismissed the charges for lack of federal jurisdiction, stating that “the federal nexus to interstate commerce necessary to create federal jurisdiction simply is not present in the case at bar.” The order stated that dismissal was jurisdictional and that “[i]n this case the court is not ruling on whether prostitution was never discussed and would never have been engaged in. If state or local prosecutorial authorities want to pursue a state law prosecution of solicitation of prostitution, that is their prerogative.” Weiner based his malicious-prosecution claim on the federal district court’s dismissal of his criminal prosecution. Health Management Associates Inc. and Teena Rowe filed a motion for partial summary judgment on the malicious-prosecution claim, arguing that a jurisdictional dismissal is not a favorable termination for the purposes of a malicious-prosecution claim. The trial court agreed. Later, with a new trial judge on the bench, Weiner asked for reconsideration. The trial court reconsidered and reversed the former judge’s order. Health Management Associates Inc. and Rowe appealed. After its review, the Mississippi Supreme Court reversed and remanded the judgment of the trial court, holding that it erred in denying the partial summary-judgment motion. View "Health Management Associates, Inc. v. Weiner" on Justia Law