The First Circuit Court of Appeals affirmed summary judgment for Massachusetts General Hospital and Dr. Alice Newton in a lawsuit brought by J.S.H., a mother who sued over a 2018 medical child abuse report that was later deemed unsubstantiated. The ruling was issued Jan. 14, 2026, in *J.S.H. v. Newton* (1st Cir. 2026).
The case centers on G.H., a child who suffered from debilitating medical conditions requiring extensive treatment throughout his short life. During G.H.'s treatment in 2018, Dr. Newton, a specialist at MGH, reported suspected medical child abuse of G.H. by his mother to authorities. Following an investigation, the report was determined to be unsubstantiated.
J.S.H. filed the federal lawsuit several years later, bringing both state-law emotional distress claims and federal claims against Dr. Newton and MGH. Among the federal claims was a disability discrimination claim against MGH under Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. § 794(a).
The case carries additional tragic context, as court records indicate that in 2011, J.S.H.'s daughter died at age four from a mitochondrial disorder. Mitochondrial disorders are long-term, often genetic conditions that adversely affect cellular energy production and can cause severe medical complications.
The U.S. District Court for the District of Massachusetts, presided over by Judge Margaret R. Guzman, granted summary judgment to both defendants. The district court concluded that J.S.H. had failed to offer sufficient facts to send the case to trial on any of her claims.
On appeal to the First Circuit, J.S.H. was represented by Luke Rosseel of Rosseel Law, along with John T. Martin, Michaela Weaver, and Sullivan & Sullivan, LLP. Dr. Newton's defense team included Christine D. Cooledge, John D. Cassidy, and Madeline P. Poole from Ficksman & Conley, LLP. MGH was represented by Emily A. Moellers, Daniel E. Murphy, and Faggiano & Associates, P.C.
Circuit Judge Rikelman wrote the opinion for a three-judge panel that also included Circuit Judges Montecalvo and Kayatta. In affirming the lower court's decision, Judge Rikelman described the matter as a "tragic case" but agreed with the district court's legal analysis.
The First Circuit's opinion focused on whether J.S.H. had presented sufficient evidence to create genuine issues of material fact that would warrant a jury trial. Under federal civil procedure rules, summary judgment is appropriate when there are no genuine disputes about material facts and the moving party is entitled to judgment as a matter of law.
The case highlights the complex legal issues that can arise when healthcare providers report suspected child abuse, particularly in cases involving children with serious medical conditions. Healthcare professionals are generally required to report suspected abuse under state mandatory reporting laws, which typically provide immunity for good faith reports.
Medical child abuse cases, sometimes referred to as medical child abuse or Munchausen syndrome by proxy, involve situations where caregivers allegedly cause or fabricate symptoms in children to gain attention or sympathy. These cases can be particularly challenging for medical professionals to identify and can lead to complex legal proceedings when reports are made.
The Rehabilitation Act claim against MGH suggests that J.S.H. alleged the hospital discriminated against her or her child based on disability status. Section 504 of the Rehabilitation Act prohibits discrimination on the basis of disability in programs or activities that receive federal financial assistance, which would include most hospitals.
The emotional distress claims likely stemmed from the impact of the child abuse investigation on J.S.H. and her family. Being investigated for child abuse can cause significant psychological harm to families, particularly when the allegations are ultimately found to be unsubstantiated.
The case number 24-1832 indicates this was among the appeals filed in the First Circuit during 2024. The First Circuit has jurisdiction over federal appeals from district courts in Maine, Massachusetts, New Hampshire, Rhode Island, and Puerto Rico.
While the specific details of the evidence presented at summary judgment are not fully outlined in the available court record, the appeals court's affirmance suggests that J.S.H. was unable to demonstrate sufficient factual disputes to overcome the defendants' motion for summary judgment on any of her claims.
The ruling serves as a reminder of the challenges faced by families dealing with complex medical conditions and the legal protections generally afforded to healthcare providers who make mandatory reports of suspected abuse in good faith. The case also underscores the high evidentiary standards required to survive summary judgment motions in federal court.
The decision appears final, as there is no indication of further appeals planned to the Supreme Court. The case reflects ongoing tensions between protecting children from abuse and protecting families from wrongful accusations in the medical setting.