CJ-2026-1606 - Bryan Hodge v. St. John Encompass Health Rehabilitation Hospital, LLC

What's This Case About?

Let’s be clear: people don’t go to rehab to get worse. But that’s exactly what Bryan Hodge says happened — he walked into a rehabilitation hospital for help, and walked out with a shattered spine, a four-hour spinal fusion surgery, meningitis, and a life now defined by chronic pain and disability. And according to his lawsuit, it wasn’t fate or bad luck — it was negligence, plain and simple, from the very people hired to protect him.

Bryan Hodge isn’t some anonymous plaintiff in a medical malpractice script. He’s a real guy from Tulsa County, Oklahoma, living with Parkinson’s disease — a condition that already makes movement unpredictable, balance sketchy, and daily life a high-wire act of medication timing and careful support. In May 2024, after a hospital stay, Bryan was admitted to St. John Encompass Health Rehabilitation Hospital in Owasso for what should’ve been routine recovery care. The facility, a for-profit rehab center run by a Delaware LLC (because of course it is), markets itself as a place of healing — skilled nursing, physical therapy, medical supervision, the whole rehab package. Bryan wasn’t there to party; he was there to get stronger. Instead, he became the victim of what his lawyers allege was a cascading series of screw-ups so avoidable, so textbook in their negligence, that it feels less like a medical oversight and more like a horror story disguised as healthcare.

Here’s how it went down, according to the petition: Bryan’s Parkinson’s meds have to be given on a precise schedule. Too early, too late, too close together — and his body rebels. Rigidity sets in. Coordination vanishes. Balance? Forget it. The hospital staff knew this. They were supposed to be managing his meds with the precision of a Swiss watch. But they weren’t. Instead, the filing claims, they administered his medications at “improper intervals,” including doses too close together — which, again, for someone with Parkinson’s, is like pouring sugar in a gas tank. The result? A sudden, preventable spike in symptoms: confusion, instability, motor dysfunction — all classic red flags that this man was now at extreme risk of falling. And yet, the system failed him.

On May 22, 2024 — just a week after admission — Bryan was being helped to the bathroom by a nurse. This wasn’t a casual stroll. He needed “moderate to maximal assistance,” according to his care plan. He was, by all accounts, entirely dependent on staff to move safely. But during the transfer, something went wrong. The staff allegedly failed to use proper transfer techniques, didn’t provide enough physical support, and ignored basic fall-prevention protocols — despite knowing Bryan was a walking (well, shuffling) liability. And so, he fell. Hard.

Now, if you’re thinking, “Okay, falls happen,” you’re not wrong — but here’s where it goes from tragic to infuriating. After the fall, Bryan immediately complained of severe leg and spinal pain — classic signs of a neurological injury. Instead of hitting the emergency brakes, ordering imaging, or calling a doctor, the staff allegedly brushed it off as “muscular.” No X-rays. No MRI. No neuro check. Nothing. Worse, they kept pushing him through aggressive physical therapy — moving a man whose spine may have already been collapsing. His condition deteriorated fast. Pain worsened. Function declined. And still, no one connected the dots.

It wasn’t until after he was discharged — yes, they let him go home — that further testing revealed the truth: a catastrophic spinal disc collapse caused by the fall. A four-hour surgery later, Bryan was fighting not just spinal damage, but complications like edema and meningitis — all because, his lawyers argue, an earlier diagnosis could’ve changed everything. This wasn’t just a fall. It was a systemic failure from the first missed medication to the last ignored cry for help.

So why are we in court? Legally, Bryan’s suing for two big things: negligence and punitive damages. The negligence claim is straightforward: the hospital had a duty to care for him safely, and they blew it. They messed up his meds, failed to prevent a foreseeable fall, botched the response, ignored red flags, and kept treating him like nothing was wrong — even as his body screamed otherwise. Each of those missteps, according to the filing, directly led to his injuries. And because those injuries happened under their watch, the hospital is on the hook — thanks to a legal principle called respondeat superior, which basically means “the boss is responsible for the employee’s screw-ups.”

But then there’s the second claim — punitive damages. That’s the legal equivalent of saying, “This wasn’t just a mistake. This was reckless.” Punitive damages aren’t about covering medical bills; they’re about punishment. They’re the court’s way of slapping a defendant and saying, “You knew better, and you did it anyway.” And here, the argument is that the hospital knew improper med timing increased fall risk, knew Bryan was unstable, knew he was in pain after the fall — and still did nothing. That’s not just negligence. That’s a conscious disregard for safety. If proven, it could open the door to extra damages meant to hurt the hospital’s wallet — and maybe, just maybe, change how they treat patients in the future.

Bryan is asking for over $75,000. Now, on paper, that might sound like a modest sum — maybe enough to cover a luxury car or a down payment on a house. But let’s be real: $75,000 doesn’t even cover a four-hour spinal surgery in 2024. We’re talking about permanent disability, chronic pain, loss of independence, ongoing medical care, possible custodial needs — not to mention the mental anguish of going into rehab to get better and coming out worse than when you arrived. In the world of medical malpractice, $75,000 is barely a starting bid. It’s almost insultingly low, which makes you wonder: is this a strategic number to keep it under a certain threshold? Or is it just the bare minimum he can ask before the insurance lawyers start laughing? Either way, it feels like a fraction of what this injury truly costs.

Here’s our take: the most absurd part isn’t even the fall. It’s what happened after. The medication error? Tragic, but human. The fall? A risk in any rehab facility. But dismissing severe spinal pain as “muscular” and then continuing aggressive therapy? That’s not just negligent — it’s cartoonishly bad medicine. Imagine your mechanic hears a grinding noise in your engine, says, “Nah, that’s just the tires,” and then floors it on the highway. That’s the energy we’re dealing with here. And let’s not ignore the irony: a rehabilitation hospital — a place literally designed to help people recover — allegedly made a man’s life permanently worse. We’re entertainers, not lawyers, but if this case proves half of what it alleges, it’s less a medical error and more a full-system failure wrapped in a hospital gown.

We’re rooting for Bryan not because he’s guaranteed to win — these cases are uphill battles, especially against corporate healthcare chains — but because someone has to stand up to the “we’ll just settle and move on” culture of hospital negligence. If a rehab facility can ignore medication protocols, dismiss patient pain, and keep pushing therapy like it’s a gym class, then who’s really being rehabilitated? And more importantly — who’s next?

Case Overview

$75,000 Demand Jury Trial Petition

Jurisdiction

District Court, Oklahoma

Filing Attorney

B. Kyle Kent

Show MO Justice, LLC

Relief Sought

$75,000 Monetary

Plaintiffs

Bryan Hodge individual
Rep: B. Kyle Kent

Defendants

St. John Encompass Health Rehabilitation Hospital, LLC business

Claims

#	Cause of Action	Description
1	negligence	Defendant's negligence led to a fall and resulting spinal injury
2	punitive damages	Defendant's reckless disregard for Plaintiff's safety

Petition Text

1,401 words

IN THE DISTRICT COURT OF TULSA COUNTY, OKLAHOMA BRYAN HODGE, ) ) FILED Plaintiff, ) vs. ) ST. JOHN ENCOMPASS HEALTH REHABILITATION HOSPITAL, LLC ) Defendant. ) PETITION FOR DAMAGES Plaintiff Bryan Hodge ("Plaintiff"), for his Petition against Defendant St. John Encompass Health Rehabilitation Hospital, LLC ("Defendant"), alleges as follows: PARTIES 1. Plaintiff Bryan Hodge is an individual resident of Tulsa County, Oklahoma. 2. Plaintiff Bryan Hodge is a resident and citizen of the State of Oklahoma. The injuries and damages alleged in this Petition occurred in Tulsa County, Oklahoma, and arise from healthcare services provided within the State of Oklahoma. The acts and omissions giving rise to Plaintiff’s claims were committed by healthcare providers operating a rehabilitation facility in Oklahoma and involve matters of substantial local concern. 3. Defendant St. John Encompass Health Rehabilitation Hospital, LLC is a Delaware limited liability company authorized to conduct business in Oklahoma and operating a rehabilitation hospital in Owasso, Tulsa County, Oklahoma. Defendant may be served through its registered agent, Corporation Service Company, 10300 Greenbrier Place, Oklahoma City, Oklahoma 73159. 4. At all times relevant, Defendant held itself out as a licensed rehabilitation hospital providing skilled nursing care, medication administration, physical therapy, and medical supervision. JURISDICTION AND VENUE 5. Jurisdiction is proper pursuant to Article VII of the Oklahoma Constitution and 12 O.S. § 2001 et seq. 6. Venue is proper in Tulsa County pursuant to 12 O.S. § 134 because the acts and omissions giving rise to this action occurred in Tulsa County, Oklahoma. FACTUAL ALLEGATIONS 7. At all relevant times, the nurses, therapists, and staff responsible for Plaintiff’s care were employees, agents, or apparent agents of Defendant acting within the course and scope of their employment and Defendant is liable for the acts and omissions of its employees and agents under the doctrine of respondeat superior. 8. Defendant owed Plaintiff a non-delegable duty to provide reasonably safe rehabilitation care, including maintaining adequate policies, training, supervision, and systems for medication administration, fall prevention, and patient monitoring. 9. Plaintiff suffers from Parkinson’s disease and other medical conditions requiring careful medication management and supervised rehabilitation services. 10. On or about May 15, 2024, Plaintiff was admitted to Defendant’s rehabilitation facility in Owasso, Oklahoma for inpatient rehabilitation care following hospitalization. 11. Plaintiff’s Parkinson’s medications required strict timing and precise administration in order to maintain safe mobility and neurological stability. 12. Defendant knew or should have known that Plaintiff required moderate to maximal assistance for transfers, had impaired balance and generalized weakness, and was at a high risk for falls requiring strict fall precautions and hands-on assistance. Such risks made a fall during assisted transfer foreseeable and preventable with proper precautions. 13. Plaintiff at all times acted reasonably and in accordance with instructions and was entirely dependent on Defendant’s staff for safe transfer and mobility. 14. Defendant, through its nurses, agents, and employees, assumed responsibility for the administration of Plaintiff’s medications and for implementing fall-prevention precautions. 15. During Plaintiff’s admission, Defendant negligently administered Plaintiff’s Parkinson’s medications at improper intervals, including administering doses too early or too close together. 16. The improper timing of Parkinson’s medications directly caused Plaintiff to experience increased rigidity, impaired coordination, imbalance, confusion, and motor instability beyond his baseline condition, thereby substantially increasing his risk of falling. 17. Defendant knew or should have known that improper Parkinson’s medication timing significantly increases fall risk. 18. On or about May 22, 2024, while being assisted by a nurse employed by Defendant to the bathroom, Plaintiff fell. 19. During the assisted transfer, Defendant’s staff failed to utilize proper transfer techniques, failed to provide adequate physical support, and failed to implement required fall-prevention measures despite Plaintiff’s known instability and need for assistance. 20. At the time of the fall, Plaintiff was under Defendant’s supervision and care. 21. Immediately after the fall, Plaintiff reported significant leg and spinal pain and experienced functional decline, which were classic indicators of potential spinal injury requiring immediate diagnostic evaluation. Defendant failed to reassess Plaintiff’s condition following the fall in accordance with accepted nursing and rehabilitation standards. 22. Defendant’s staff dismissed Plaintiff’s complaints as muscular in nature and failed to obtain appropriate diagnostic imaging or physician evaluation. 23. Defendant continued aggressive physical therapy despite Plaintiff’s worsening condition and complaints of severe pain. 24. Plaintiff’s condition deteriorated rapidly following the fall. 25. Plaintiff had no prior history of acute spinal collapse or comparable neurological deterioration of the type diagnosed after the fall. Immediately following the fall, Plaintiff experienced new and worsening spinal pain, leg dysfunction, and functional decline. Within days following discharge from Defendant’s facility, further medical evaluation revealed the extent of Plaintiff’s spinal injury. 26. Plaintiff’s injuries were not the result of a natural progression of any preexisting condition, but were directly caused by the traumatic fall and Defendant’s failure to timely diagnose and treat the resulting injury. 27. Subsequent medical evaluation and imaging confirmed that Plaintiff suffered a catastrophic spinal disc collapse caused by the traumatic fall described herein. 28. Plaintiff required an extensive spinal surgery lasting approximately four hours. 29. Plaintiff’s condition further deteriorated, requiring intensive care treatment, and he suffered serious complications including edema and meningitis requiring additional invasive procedures. Earlier diagnosis would have prevented or significantly reduced the severity of Plaintiff’s injuries and complications. 30. As a direct and proximate result of Defendant’s negligence, Plaintiff sustained severe and permanent injuries including spinal injury, neurological impairment, chronic pain, loss of mobility, bowel and bladder dysfunction, loss of independence, and the need for ongoing medical and custodial care. No independent or superseding cause contributed to Plaintiff’s injuries. Each of the foregoing acts and omissions, individually and collectively, directly and proximately caused Plaintiff’s injuries. COUNT I – NEGLIGENCE 31. Plaintiff incorporates the preceding paragraphs as if fully set forth herein. 32. Defendant owed Plaintiff a duty to exercise the degree of care, skill, and learning ordinarily possessed and exercised by rehabilitation hospitals and healthcare providers under similar circumstances. 33. Defendant breached its duty of care by, including but not limited to, failing to properly administer Parkinson’s medications, failing to properly monitor medication timing, failing to properly assess fall risk, failing to implement appropriate fall-prevention precautions, failing to safely assist Plaintiff during transfers, failing to reassess Plaintiff following the fall, failing to timely order diagnostic imaging, failing to monitor neurological deterioration, failing to provide appropriate supervision, continuing therapy despite red-flag symptoms, and failing to follow accepted standards of rehabilitation medicine, nursing care, and patient safety. 34. Upon information and belief, Defendant had prior notice of similar incidents involving medication administration errors, patient falls, or inadequate supervision at its facility and failed to take reasonable steps to correct or prevent such occurrences. 35. Defendant further breached its duties by failing to adequately train, supervise, and monitor its employees responsible for administering medications and supervising Plaintiff during transfers and mobility assistance, thereby creating an unreasonable risk of harm to patients such as Plaintiff. 36. As a direct and proximate cause of Defendant’s breach of duty, Plaintiff has suffered severe and permanent bodily injury, past and future medical expenses, pain and suffering, mental anguish and emotional distress, loss of enjoyment of life, loss of earning capacity, permanent disability, and increased need for medical and custodial care. WHEREFORE, as a result of Defendant’s negligence, Plaintiff claims all damages listed above in an amount in excess of Seventy-Five Thousand ($75,000.00) Dollars and any other relief to which he is entitled. COUNT II – PUNITIVE DAMAGES 37. Plaintiff incorporates the preceding paragraphs as if fully set forth herein. 38. Plaintiff alleges that Defendant’s conduct demonstrated reckless disregard for the rights and safety of Plaintiff. 39. Defendant knew or should have known that improper medication management and failure to respond to post-fall symptoms created a high probability of serious injury, including conscious disregard of known and obvious risks to Plaintiff’s safety. 40. Defendant acted with reckless disregard for Plaintiff’s safety by continuing therapy and failing to obtain diagnostic evaluation despite obvious signs of neurological injury following the fall. 41. Plaintiff is entitled to punitive damages pursuant to 23 O.S. § 9.1. WHEREFORE, Plaintiff prays for judgment against Defendant as follows: compensatory damages in an amount in excess of $75,000; punitive damages as allowed by law; costs of this action; pre- and post-judgment interest as allowed by law; and such other and further relief as the Court deems just and proper. Respectfully submitted, By /s/ Kyle Kent B. Kyle Kent, OBA# 36336 Show MO Justice, LLC 205 Park Central East, Ste 518 Springfield, MO 65806 (Office) 417-530-4560 (Fax) 417-530-4560 [email protected] Attorney for Plaintiff ATTORNEY LIEN CLAIMED JURY TRIAL DEMANDED