The Ninth Circuit Court of Appeals reversed a lower court's dismissal of a wrongful death lawsuit filed by Washington residents against Idaho medical providers, clearing the way for the case to proceed in federal court. The court held that personal jurisdiction requirements were satisfied despite the cross-border nature of the medical malpractice claims.

In *Cox v. Gritman Medical Center*, the appellate court ruled that the U.S. District Court for the Eastern District of Washington properly had jurisdiction over Gritman Medical Center and Dr. Patricia N. Marciano, despite both defendants being Idaho residents who provided medical treatment in Idaho.

The case stems from the death of Susan Cox, a Washington resident who lived in Albion with her husband Mark Cox. Susan Cox died from what the lawsuit alleges was a fatal overdose related to Dr. Marciano's over-prescription of pharmaceutical drugs. Dr. Marciano served as Susan Cox's primary care physician.

Following Susan Cox's death, her estate and Mark Cox filed the wrongful death and survivor action in the Eastern District of Washington. The defendants moved to dismiss the case for lack of personal jurisdiction, arguing that as Idaho residents providing medical care in Idaho, they could not be subject to jurisdiction in Washington federal court.

The district court initially granted the motion to dismiss, finding insufficient contacts between the defendants and Washington state to establish personal jurisdiction. However, the Ninth Circuit disagreed, noting that the medical providers' location near the Washington border and their deliberate cultivation of patient relationships with Washington residents created sufficient minimum contacts to satisfy due process requirements for personal jurisdiction.