Judge: Cherol J. Nellon, Case: 23STCV18738, Date: 2024-07-03 Tentative Ruling
Case Number: 23STCV18738 Hearing Date: July 3, 2024 Dept: 14
#13
Case Background
Plaintiffs’ father, Kevin Marine
(“Decedent”) was a resident at a nursing home who was attacked and killed by
another resident, John Greystoke (“Greystoke”). Plaintiffs allege that Defendants
failed to properly address Greystoke’s mental health needs and thereby enabled
the attack.
On August
8, 2023, Plaintiffs filed their Complaint for (1)-(3) Wrongful Death, (4) Negligent
Supervision, Hiring, and Training, (5) Breach of Fiduciary Duty, (6) Elder
Abuse, (7) Survival Action, (8) Negligence, and (9) Violation of Resident’s
Bill of Rights against Defendants Crenshaw Nursing Home, LLC dba Crenshaw
Nursing Home (“Crenshaw”), Longwood Management, LLC (“Longwood”), and DOES 1-500.
The first, second, fifth, sixth, and ninth causes of action are asserted
against Crenshaw and Does 1-500. The third cause of action is asserted against
Longwood and Does 3-500. The fourth, seventh, and eighth causes of action are
asserted against all defendants.
On October
5, 2023, Crenshaw and Longwood filed their Answer.
On January
26, 2024, this case was assigned to this court from the Personal Injury Hub.
Trial is currently set for April
28, 2025.
Instant Motion
Plaintiff Justine Marie now moves this court, per Code of Civil Procedure
§§ 473(a)(1), 576, and 426.50, for leave to file a First Amended Complaint, add
to this lawsuit two defendants, William Elliott (“Elliott”) and Dr. Rajendra
Prasad (“Prasad”), and two additional causes of action for wrongful death.
Decision
The motion is GRANTED. Plaintiffs
are ordered to file the First Amended Complaint appended to the Declaration of
Michael Murphy, which will be deemed the operative complaint in this action.
Governing
Standard/Statute
Code of Civil Procedure
§ 473(a) vests the court with discretion, after a noticed motion, to allow
any party to amend any pleading. The motion must comply with the requirements
set forth in California Rules of Court Rule 3.1324, which states as follows:
(a) Contents of motion
A motion to amend a pleading before
trial must:
(1)
Include a copy of the proposed amendment or amended
pleading, which must be serially numbered to differentiate it from previous
pleadings or amendments.
(2)
State what allegations in the previous pleading are
proposed to be deleted, if any, and where, by page, paragraph, and line number,
the deleted allegations are located; and
(3)
State what allegations are proposed to be added to the
previous pleading, if any, and where, by page, paragraph, and line number, the
additional allegations are located.
(b) Supporting declaration
A separate declaration must
accompany the motion and must specify:
(1) The effect of the amendment;
(2) Why the amendment is necessary and proper;
(3) When the facts giving rise to the amended
allegations were discovered; and
(4) The
reasons why the request for amendment was not made earlier . . .
(CRC 3.1324(a) and (b), emphasis added.)
“[T]he court’s discretion will
usually be exercised liberally to permit amendment of the pleadings.
[Citations]. The policy favoring amendment is so strong that it is a rare case
in which denial of leave to amend can be justified.” Howard v. County of San
Diego (2010) 184 Cal.App.4th 1422, 1428. It is an abuse of
discretion to deny leave to amend based on delay alone; the amendment must
affirmatively prejudice the opposing side. Higgins v. Del Faro (1981)
123 Cal.App.3d 558, 564-565. Prejudice exists where the delay is unwarranted
and the result will be additional cost for trial preparation, witness
depositions, and other discovery. See Doe v. Los Angeles County Dept. of
Children & Family Services (2019) 37 Cal.App.5th 675, 689
(citing Melican v. Regents of University of California (2007) 151
Cal.App.4th 168, 175); P&D Consultants, Inc. v. City of
Carlsbad (2010) 190 Cal.App.4th 1332, 1345 (citing Huff v.
Wilkins (2006) 138 Cal.App.4th 732, 746).
Discussion
Plaintiff’s
motion meets the procedural requirements for bringing a motion for leave to
amend. The Declaration of Mr. Murphy includes a proposed FAC and identifies the
proposed changes to the Complaint. (See Murphy Decl.) Exhibit 3 of the Murphy
Declaration is a redline comparing the Complaint and proposed FAC. Plaintiff seeks to add two defendants,
William Elliott (“Elliott”) and Dr. Rajendra Prasad (“Prasad”), and a cause of
action for wrongful death as to each of them.
The Court finds that good cause
exists to allow the amendment.
Elliott works as an admission coordinator at Crenshaw. (Murphy Decl., ¶
32.) One of his job duties is to evaluate a prospective patient’s suitability
before they are admitted into the nursing home. (Ibid.) On January 20, 2023,
Elliott, against protocol, escorted Greystone out of the nursing home to a
nearby liquor store where Greystone acquired the knife that he used to attack
Decedent. (Id., ¶ 34; Compl., ¶ 24.) Plaintiffs discovered Elliott’s name on
December 4, 2023, when Crenshaw produced Greystoke’s medical file. (Murphy
Decl., ¶ 32.) However, Crenshaw did not release Elliott’s address and telephone
number until May 9, 2024. (Id., ¶ 35.)
Prasad was Greystoke’s treating physician at the Southern California
Hospital at Culver City immediately before Greystoke was admitted to the
nursing home. (Id., ¶ 26.) At the same time, Prasad also served as a medical
director for Crenshaw. (Id., ¶ 30.) Greystoke’s record shows that he has a
criminal history and violent propensities, and that he was prescribed
medication to treat schizophrenia. (Id., ¶ 28.) Yet, Crenshaw never once
administered this medication to Greystoke. (Ibid.) Crenshaw compensated Prasad
for referring patients to the nursing home. (Id., ¶ 30.) Prasad’s dual role
raises concerns for conflict of interest. (Ibid.) Plaintiffs discovered this
information on March 11, 2024. (Id., ¶ 28.) On March 27, 2024, Plaintiffs sent
a letter to Prasad to fulfil the notice requirement of CCP § 364 (actions based
upon healthcare provider’s negligence require 90-day notice to defendants).
Therefore, Prasad only recently became available to be brought into this
action.
Defendants oppose the motion on the grounds that it would prejudice
Defendants in the form of additional discovery. However, there is no showing
that Plaintiffs’ delay in seeking to bring Elliott and Prasad into the action
is unwarranted. Instead, Defendants merely state, in a conclusory manner, that
Plaintiff “conveniently glosses over the timeline of events”. (Opp’n, 6:8.)
Conclusion
There is good cause for the amendment, and Defendants have not shown
undue prejudice.
The motion is GRANTED. Plaintiffs are ordered to file the First Amended
Complaint appended to the Declaration of Michael Murphy, which will be deemed
the operative complaint in this action.