Judge: Alison Mackenzie, Case: 23STCV19225, Date: 2024-05-15 Tentative Ruling

Case Number: 23STCV19225    Hearing Date: May 15, 2024    Dept: 55

NATURE OF PROCEEDINGS: Defendant Brenda Mandelbaum’s Demurrer to Plaintiff’s First Amended Complaint. Defendant Brenda Mandelbaum’s Motion to Strike Portions of Plaintiff’s First Amended Complaint. Janet Mandelbaum’s Demurrer to Plaintiff’s First Amended Complaint. Janet Mandelbaum’s Motion to Strike Portions of Plaintiff’s First Amended Complaint. Defendant Simcha Mandelbaum's Demurrer to Plaintiff's First Amended Complaint. Defendant Simcha Mandelbaum's Motion to Strike Portions of Plaintiff's First Amended Complaint. 

BACKGROUND

ALAN TONKINS (“Tonkins”), in and through his Successor-In-Interest, JOSHUA TONKINS and JOSHUA TONIKINS (“Plaintiffs”) bring this case against GUARDIAN REHABILITATION HOSPITAL; 533 SOUTH FAIRFAX AVENUE, INC. dba GUARDIAN REHABILITATION HOSPITAL; SKILLSERVE, INC. dba US SKILLED SERVE; JANET MANDELBAUM; BRENDA MANDELBAUM; and SIMCHA MANDELBAUM for damages arising out of Tonkins’s stay at the skilled nursing facility owned and managed by Defendants. The First Amended Complaint (“FAC”) asserts the following causes of action against Defendants Janet Mandelbaum, Brenda Mandelbaum, and Simcha Mandelbaum (collectively, “Mandelbaum Defendants”): (1) Elder Abuse, Welfare and Institutions Code Sections 15600, et seq., (2) Negligence (4) Willful Misconduct, and (5) Wrongful Death, Code of Civil Procedure Section 377.60.

Each of the Mandelbaum Defendants filed demurrers to the entire FAC, and to all the claims except the Third Cause of Action. Each of the Mandelbaum Defendants also filed motions to strike certain prayers for damages and other allegations. The arguments in the three demurrers and three motions to strike are essentially the same and so the Court has advanced the hearing on Simcha Mandelbaum’s demurrer and motion to strike to 5/15/24 and considers all the demurrers and motions to strike in this tentative ruling. Plaintiffs oppose the demurrers and motions to strike.

LEGAL STANDARD

Demurrers are to be sustained where a pleading fails to plead adequately any essential element of the cause of action. Cantu v. Resolution Trust Corp. (1992) 4 Cal.App.4th 857, 879-880.

Regarding uncertainty, "[t]here is no need to require specificity in the pleadings because 'modern discovery procedures necessarily affect the amount of detail that should be required in a pleading.'” Ludgate Ins. Co. v. Lockheed Martin Corp. (2000) 82 Cal.App.4th 592, 608.

The grounds for a motion to strike are that the pleading has irrelevant, false or improper matter, or has not been drawn or filed in conformity with laws.  Code Civ. Proc., § 436. 

ANALYSIS

1.      Demurrers

A.    Individual Liability

The Mandelbaum Defendants argue that the entire FAC is uncertain because it is pleaded globally or collectively as to all defendants and fails to specify actionable conduct or elder abuse by them. Additionally, the Mandelbaum Defendants contend that the licensed facility has non-delegable duties that they do not have.

If the allegations for negligence “show plainly the connection between cause and effect, it suffices to plead causation succinctly and generally.” Bockrath v. Aldrich Chemical Co. (1999) 21 Cal.4th 71, 78. In such cases alleging conduct of defendants and each of them is sufficient to charge each with liability. E.g., Lee v. Escrow Consultants, Inc. (1989) 210 Cal.App.3d 915, 925.

The Elder Abuse Act applies to defendants having had a caretaking or custodial relationship with an elder or dependent adult, including health care providers, administrators or employees of health facilities, persons providing care or services, members of support and maintenance staff, nursing homes, and clinics. Winn v. Pioneer Medical Group, Inc. (2016) 63 Cal.4th 148, 163-165.

“[J]oint venturers,… are jointly and severally liable to third parties for the obligations of the joint venture ….” Victor Valley Transit Auth. v. Workers' Comp. Appeals Bd. (2000) 83 Cal.App.4th 1068, 1076. A jury found individuals engaged in a joint venture were liable for elder abuse. See Cochrum v. Costa Victoria Healthcare, LLC (2018) 25 Cal.App.5th 1034, 1043.

 

Here, the FAC alleges that each Mandelbaum Defendant had control over operations, such as by being directors. E.g., FAC, ¶¶ 31-35 and 96-133. Further, each Mandelbaum Defendant acted as care custodians. E.g., FAC, ¶¶ 37-38. In addition, there are global allegations attributing alleged conduct to all defendants, which is permissible, because allegations adequately state that a bladder puncture and catheter non-removal occurred, which naturally infers causation of personal injuries and related complications such as sepsis. Also, the FAC alleges that all Defendants (including the Mandelbaum Defendants) allegedly were a joint enterprise and venture jointly and severally liable. E.g., FAC, ¶¶ 17, 37 and 134-137.

“[W]hile a plaintiff can look to either the vicariously liable defendant or the actively negligent defendant to pay these damages, the plaintiff cannot recover these same damages from both.” Schreiber v. Lee (2020) 47 Cal.App.5th 745, 761.  The issue of double recovery arises during or after trial, not in the pleading phase.  Specifically, parties may initially pursue a double recovery, and make an election of remedies at trial or after. De Anza Santa Cruz Mobile Estates Homeowners Assn. v. De Anza Santa Cruz Mobile Estates (2001) 94 Cal.App.4th 890, 907. Thus, by law, Plaintiffs may litigate against both the entity having nondelegable duties or vicarious liability, and the actively negligent agents, until any issue of double recovery comes up during trial.

Therefore, the Court overrules the demurrers as to the questions of individual liability.

 

B.     First Cause of Action for Elder Abuse

The Mandelbaum Defendants argue that the elder abuse claim fails because they had no caretaking or custodial relationship with Tonkins and because the FAC does not allege intentional malice. The Court disagrees.

Various theories may support claims for elder abuse, beyond just directly caregiving for a resident. See, e.g., Fenimore v. Regents of Univ. of Cal. (2016) 245 Cal.App.4th 1339, 1349  (demurrer should have been overruled, where plaintiff alleged hospital health care facility had a pattern and knowing practice of understaffing, recklessly causing injury); Sababin v. Superior Court (2006) 144 Cal.App.4th 81, 90 (if a health care facility knows it must provide a certain type of care on a daily basis but provides it sporadically, or is supposed to provide multiple types of care but only provides some, then the withholding of care may constitute more than negligence, and reckless conduct, in support of heightened remedies, where a trier of fact finds a significant pattern of withholding medical care.); Carter v. Prime Healthcare Paradise Valley LLC (2011) 198 Cal.App.4th 396, 407  (“the facts constituting the neglect and establishing the causal link between the neglect and the injury ‘must be pleaded with particularity,’ in accordance with the pleading rules governing statutory claims.”); Stewart v. Superior Court (2017) 16 Cal.App.5th 87, 108  (triable issues regarding whether medical entity’s decision-making structure, and doctor’s decision about treatment, were beyond professional negligence and instead reckless);  Intrieri v. Superior Court (2004) 117 Cal. App. 4th 72, 85 (determining triable issue existed regarding reckless neglect in not providing medical care);  Benun v. Superior Court  (2004) 123 Cal.App.4th 113, 126 (“the intent of the Elder Abuse Act is to subject health care providers to its ‘heightened remedies’ when their acts or omissions are reckless or willful and, thus, more culpable than professional negligence.”); Worsham v. O'Connor Hospital (2014) 226 Cal. App. 4th 331, 338 (alleged failures to provide a doctor-recommended sitter to prevent fall, understaffing and undertraining, amounted to professional negligence lacking in specific facts indicating any recklessness, defined as a conscious choice of action done with knowledge of serious danger to others involved).

The FAC alleges that each Mandelbaum Defendant consciously disregarded their duties to provide care for Tonkins as a resident, and created probable, serious injury. E.g., FAC, ¶¶ 43-44. The Mandelbaum Defendants allegedly recklessly disregarded Plaintiff’s safety, while knowing there would be a probability of injury or death. E.g., FAC, ¶¶ 149 and 176-177. The Mandelbaum Defendants allegedly consciously understaffed the facility because they put their financial interests above the residents’ interests. E.g., FAC., ¶¶ 85-86. Causation is clearly alleged, including Defendants not removing a catheter from Plaintiff, thereby blocking urine output, long-term. E.g., FAC, ¶¶ 53-58. Defendants consciously and knowingly the physician’s order regarding treatment. E.g., FAC, ¶ 65. Defendants, as care custodians, abandoned and abused the care of Plaintiff, leading to his suffering sepsis, bladder perforation, abdominal ascites, urinary tract infection, acute kidney injury, and eventually death. E.g., FAC, ¶ 46. In the demurrer procedure, the Mandelbaum Defendants cannot properly contradict such allegations, by stating that they had no caretaking or custodial relationship. Gould v. Maryland Sound Industries, Inc. (1995) 31 Cal.App.4th 1137, 1144 (“defendants cannot set forth allegations of fact in their demurrers which, if true, would defeat plaintiff's complaint”).

Also, the prescribed procedure for getting more details to address any uncertainty is conducting discovery.

Hence, the Court overrules the demurrers as to the claim for elder abuse.

C.     Second Cause of Action for Negligence

The Mandelbaum Defendants do not specifically address the negligence claim listed in the notices, other than as to individual liability and uncertainty, which the Court has already addressed above. The demurrers to this claim are overruled.

D.    Fourth Cause of Action for Willful Misconduct

The Mandelbaum Defendants contend that this claim fails because California law does not recognize an independent cause of action for “willful misconduct.”

There is a split of authority on the issue. See, e.g., Nazar v. Rodeffer (1996) 184 Cal.App.3d 546, 552, disapproved on other grounds by Ornelas v. Randolph (1993) 4 Cal.4th 1095, 1108; New v. Consolidated Rock Products Co. (1985) 171 Cal. App. 3d 681, 689; Bastian v. County of San Luis Obispo (1988) 199 Cal. App. 3d 520, 533; Carter v. Prime Healthcare Paradise Valley LLC (2011) 198 Cal.App.4th 396, 412  (“Willful misconduct involves more than a failure to use ordinary care….”); Calvillo-Silva v. Home Grocery (1998) 19 Cal.4th 714, 730, disapproved on other grounds by Aguilar v. Atlantic Richfield Co. (2001) 25 Cal.4th 826, 854, fn. 19; Acosta v. Glenfed Development Corp. (2005) 128 Cal.App.4th 1278, 1293. But see Berkley v. Dowds (2007) 152 Cal.App.4th 518, 526 (willful misconduct is an aggravated form of negligence).

Where there is a split of authority, trial courts have discretion to choose between the decisions.  Auto Equity Sales, Inc.  v.  Superior Court (1962) 57 Cal.2d 450, 456. Where there is a split of authority, “[a]s a practical matter, a superior court ordinarily will follow an appellate opinion emanating from its own district even though it is not bound to do so.” McCallum v. McCallum  (1987) 190 Cal.App.3d 308, 316, fn.4.

Here, the Court, in its discretion, will follow the great weight of authority, and not the isolated authority cited for support in the demurrers— i.e., Berkley, supra. The Court also disregards the Mandelbaum Defendants’ argument in the reply briefs that the claim fails to allege sufficient facts because they failed to raise such an argument in their moving papers and improperly raised it for the first time in the reply briefs. The Court overrules the demurrers as to willful misconduct.

E.     Fifth Cause of Action for Wrongful Death

The Mandelbaum Defendants contend that Plaintiffs’ allegations do not establish a causal connection between their wrongful conduct and Tonkins’s death, nor do the allegations give rise to such an inference.

A wrongful death claim requires “(1) a wrongful act or neglect on the part of one or more persons that (2) causes (3) the death of another person.” Norgart v. Upjohn Co. (1999) 21 Cal. 4th 383, 390. “In any action for wrongful death resulting from negligence, the complaint must contain allegations as to all the elements of actionable negligence.” Jacoves v. United Merchandising Co (1992) 9 Cal.App.4th 88, 105.

Under the topics of individual liability and elder abuse, the Court already addressed the sufficiently particular factual allegations supporting the negligence claim that gives rise to the wrongful death claim. Therefore, the Court overrules the demurrers as to wrongful death.

2.      Motions to Strike

A.    Section 425.13

The Mandelbaum Defendants contend that the elder abuse claim is based on allegations only constituting professional negligence by a healthcare provider, such that an order allowing leave to allege punitive damages pursuant to Code of Civil Procedure Section 425.13 is required.

Section 425.13 does not apply to an elder abuse claim. Covenant Care, Inc. v. Superior Ct. (2004) 32 Cal. 4th 771, 783-790. As analyzed as to the demurrers, the FAC sufficiently alleges elder abuse, and not merely professional negligence. Thus, the Court denies the motions to strike allegations based upon Section 425.13.

B.     Punitive Damages

The Mandelbaum Defendants assert that they did not have care or custody of Plaintiff and cannot be liable for punitive damages under the Elder Abuse Act. Further they assert that the FAC fails to specifically allege fraud, oppression, or malice.

“In order to survive a motion to strike an allegation of punitive damages, the ultimate facts showing an entitlement to such relief must be pled by a plaintiff.” Clauson v. Superior Court (1998) 67 Cal.App.4th 1253, 1255. Generally, “punitive damages may be recovered in medical malpractice cases depending upon the facts of the particular case.” Baker v. Sadick (1984) 162 Cal.App.3d 618, 630.

“To recover enhanced remedies under the [Elder Abuse] act, ‘a plaintiff must prove more than simple or even gross negligence in the provider’s care or custody of the elder.’” Nevarrez v. San Marino Skilled Nursing and Wellness Centre (2013) 221 Cal.App.4th 102, 128. For corporations to be liable for punitive damages, a director or managing agent may have done the conduct, but also liability may include knowledge of an employee's unfitness and disregard the rights of others, or authorized or ratified the conduct. Myers v. Trendwest Resorts, Inc. (2007) 148 Cal.App.4th 1403, 1436.

As addressed with respect to the demurrers, the FAC sufficiently alleges each Mandelbaum Defendant’s status as a caregiver and custodian, which is to be assumed true for purposes of the motion to strike. Kaiser Foundation Health Plan, Inc. v. Superior Court (2012) 203 Cal.App.4th 696, 699, fn.1. Further, the FAC alleges the Mandelbaum Defendants’ conscious disregard of a high degree of probability that Tonkins could suffer injuries. Also, each Mandelbaum Defendant acted through managing agents and approved or ratified the alleged acts and omissions. E.g., FAC, ¶¶ 39, 73 and 80.

Thus, the Court denies the motions as to punitive damages.

C.     Attorneys’ Fees

The Mandelbaum Defendants reason that Plaintiffs have not adequately pled specific facts under the Elder Abuse Act to be entitled to attorney's fees.

Unsupported attorneys’ fees allegations need not be stricken pursuant to a motion to strike because later discovery may reveal a basis for their recovery. Camenisch v.  Superior Court  (1996) 44 Cal.App.4th 1689, 1699. “There is no requirement that a party plead that it is seeking attorney fees, and there is no requirement that the ground for a fee award be specified in the pleadings.” Yassin v. Solis  (2010) 184 Cal.App.4th 524, 533.

While there is no standard for pleading attorneys’ fees, the FAC sufficiently alleges the Elder Abuse Act as being supportive. See Covenant Care, Inc. v. Sup. Ct.  (2004) 32 Cal.4th 771, 789 (“In order to obtain the Act’s heightened remedies, a plaintiff must allege conduct essentially equivalent to conduct that would support recovery of punitive damages.”); Marron v. Superior Court (2003) 108 Cal.App.4th 1049, 1058, 1063, fn.11 (Welfare and Institutions Section 15657 provides for recovery of damages for a decedent's pain and suffering—a type of compensatory damages, and “enhanced remedies include awards of reasonable attorney fees and costs and limited damages for a decedent's pain and suffering….”).

Therefore, the motions are denied as to alleging attorneys’ fees.

D.    Special Damages Prayer

The Mandelbaum Defendants assert that special damages must be alleged with support and statements of amounts.

Generally, with exceptions, special damages must be pleaded with some specificity. 5 Witkin, Cal. Proc. 6th Plead § 932 (2024) (citing several opinions from the early and middle 1900s). Older case authority may be impliedly overruled by a later trend of decisions, without an opinion expressly overruling. Frisk v. Sup.Ct. (2011) 200 Cal.App.4th 402, 411. Modernly, a court errs in striking a prayer for damages, where the plaintiff sufficiently stated a supportive cause of action. Ruiz v. Musclewood Inv. Properties, LLC (2018) 28 Cal.App.5th 15, 24–25.

The FAC adequately alleges types of special damages, including medical expenses, as elements of supportive causes of action. See, e.g., FAC, ¶ 162 (“incurred, losses, including medical expenses in an amount to be proven at trial in excess of the minimum jurisdictional limits….”). Cf., Ducat v. Goldner (1946) 77 Cal.App.2d 332, 338 (the pleading sufficiently alleged unknown medical charges as a part of special damages such that the defendant could have learned specifics via discovery).

Hence, the Court denies the motions as to the prayer for special damages.

E.     Pleading Conclusions

The Mandelbaum Defendants contend that certain allegations are conclusory and can be stricken. Conclusory language in pleading allegations is not subject to a motion to strike where the full context of the complaint contains sufficient facts alleged to support the conclusions. Perkins v. Superior Court (1981) 117 Cal.App.3d 1, 6–7.

While the opinion cited in the motions held that conclusions properly were stricken, it did not address whether the full context of the pleading contained support for those conclusions. See Simpson v. Richmond (1957) 154 Cal.App.2d 27, 32. “[A]n unnecessarily broad holding is ‘informed and limited by the fact[s]’ of the case in which it is articulated.” Covenant Care, Inc. v. Superior Court (2004) 32 Cal.4th 771, 790.

As analyzed regarding the demurrers, the FAC contains allegations sufficiently supportive of each attacked claim, such that the purportedly conclusory allegations are not subject to a motion to strike.  

Hence, the Court declines all the motions’ requests to strike the alleged conclusions.

CONCLUSION

The Court overrules the demurrers and denies the motions to strike. Twenty days to answer.