A New York Supreme Court judge ruled on April 1, 2026, in a medical malpractice case involving the late Clement R. Landanno. The court's decision impacts several healthcare providers and raises questions about their responsibilities in patient care, particularly regarding dialysis treatment. The ruling is significant for families navigating similar medical malpractice claims.
The case, Landanno v. Kwon (Index No. 2023-53414), centers on allegations of wrongful death and medical malpractice against multiple healthcare professionals and facilities. The plaintiff, Antje Anita Landanno, is the executrix of her late husband's estate, claiming negligence led to his death after he was discharged from a hospital without proper arrangements for necessary dialysis treatment.
Clement R. Landanno was admitted to Mid-Hudson Regional Hospital (MHRH) in July 2022 for bladder cancer surgery. Following complications, he required hemodialysis three times a week. After his surgery, he was discharged to Putnam Ridge, a nursing home, on August 18, 2022. However, he did not receive dialysis on the following Friday or thereafter. On August 22, 2022, he suffered cardiac arrest and was pronounced dead shortly after arriving at Danbury Hospital. An emergency physician noted that the lack of dialysis likely contributed to his death.
Antje Landanno filed the lawsuit on August 10, 2023, against several defendants, including Dr. Lawrence Kwon, Dr. Muhammad Khan, and various staff members at MHRH and Putnam Ridge. The case later consolidated with related claims against additional defendants, including Dr. Sonal Parmar and Bon Secours Charity Health System Medical Group.
The court's ruling addressed multiple motions for summary judgment, where defendants sought to dismiss the claims against them. Judge Maria G. Rosa presided over the case and issued a comprehensive opinion detailing the responsibilities of healthcare providers in discharge planning and patient care.
In her ruling, Judge Rosa stated, "The decision to discharge [Decedent] on August 18 was pursuant to the standard of care and constituted good and accepted practice." The court found that Dr. Kwon had no involvement in the discharge planning and was entitled to dismissal of the claims against him. Similarly, the court dismissed claims against Dr. Gorich, who was also found not liable.
However, the court did not dismiss all claims. The judge noted that there were triable issues of fact regarding the actions of certain defendants, particularly social worker Sara Beliveau. The court found that Beliveau may have failed to ensure that dialysis services were secured before Mr. Landanno's discharge. Judge Rosa highlighted that the failure to ascertain whether Putnam Ridge could provide the necessary dialysis may have contributed to the circumstances leading to his death.
"The remaining allegations must be dismissed as against Defendant Beliveau, as Plaintiff's experts fail to address them," Judge Rosa wrote. This ruling indicates that while some defendants were cleared of liability, others may still face scrutiny in court.
The ruling has significant implications for healthcare providers and patients alike. It emphasizes the importance of ensuring that patients receive necessary medical treatments after discharge. The court's decision reinforces the responsibility of healthcare providers to communicate effectively and plan for continuity of care, especially for patients requiring ongoing treatments like dialysis.
Moving forward, the ruling sets a precedent regarding the obligations of healthcare providers in discharge planning. It may influence how hospitals and nursing homes coordinate care for patients with complex medical needs. Families dealing with similar situations may find this ruling relevant as they navigate medical malpractice claims.
As for what’s next, the case is not over. The court scheduled a pretrial settlement conference for April 14, 2026, and jury selection is set for May 18, 2026. The remaining defendants, including Jeanne Hubner and Putnam Ridge, will continue to face claims related to their alleged negligence in providing adequate care to Mr. Landanno.
Details were not available in the court filing regarding any potential appeals. However, the outcome of the upcoming trial could further clarify the legal standards for medical malpractice in New York.