Judge: Frank M. Tavelman, Case: 21STCV18294, Date: 2023-08-11 Tentative Ruling

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Case Number: 21STCV18294    Hearing Date: January 8, 2024    Dept: A

LOS ANGELES SUPERIOR COURT

NORTH CENTRAL DISTRICT - BURBANK

DEPARTMENT A

 

RULING ON SUBMITTED MATTER

JANUARY 8, 2024

MOTION FOR SUMMARY JUDGMENT / ADJUDICATION

BHC ALHAMBRA HOSPITAL

Los Angeles Superior Court Case # 21STCV18294

 

MP:    BHC Alhambra Hospital (Defendant)

RP:     Olga Zharovskaya (Plaintiff)

 

NOTE:   For convenience of expedited access by counsel, the Court is posting this matter on the Tentative Ruling website; however, it is a Ruling on the Submitted Matter.

 

The Court issued a Tentative Ruling and heard argument on December 18, 2023.  While the moving party argued for the complete summary judgment, they strongly encouraged the court to reevaluate the initial denial of the summary adjudication as to the second and third causes of actions, Dependent Adult Abuse and Willful Misconduct.  Plaintiff argues that BHC’s reference to a higher standard that the neglect was committed with recklessness, malice, oppression or fraud was misplaced in that it applied to enhanced damages only.  Defendant cites to, inter alia,  Delaney v. Baker (1999) 20 Cal. 4th 23, 32 to support their position, but Plaintiff argued that the heighted requirements are for heightened damages under the statute and not for regular damages.   The Court concurs.   While the Plaintiff may not ultimately be able to show heightened damages under the statute, that does not alter their ability to show regular damages against a party that is in a caretaker capacity.  The Court will adopt its tentative as the Court’s final ruling; however, the Court inadvertently overlooked addressing the issue of punitive damages which is addressed herein.

 

ALLEGATIONS:

 

On May 14, 2023, Olga Zharovskaya (“Plaintiff”) filed suit against BHC Alhambra Hospital (“Defendant”). Plaintiff alleges Defendant was negligent in her care and in the supervision of a third-party patient (“TPP”) who attacked Plaintiff while she was a patient at Defendant’s hospital. The Complaint contains causes of action for (1) Professional Negligence, (2) Dependent Adult Abuse, and (3) Willful Misconduct.

 

Defendant now moves for summary judgment. Defendant argues no triable issue of fact exists as to whether the actions of its staff in caring for Plaintiff fell below the standard of care. In the alternative, Plaintiff moves for summary adjudication of Plaintiff’s second and third causes of action. Plaintiff opposes and Defendant replies.

 

The matter was originally on the Court’s calendar for December 15, 2023, which the Court on its own motion continued to December 18, 2023 at 9:00 a.m.  The matter was argued and taken under submission.

 

EVIDENTIARY OBJECTIONS:

 

Plaintiff’s evidentiary objections to the declaration of Denise K. Rounds are OVERRULED. Plaintiff objects to the entirety of the declaration on grounds that Rounds, a registered nurse, is not a qualified expert for purposes of opining on the standard of care. As Plaintiff notes, Evidence Code § 720(a) states, “a person is qualified to testify as an expert if her has special knowledge, skill, expertise, training, or education sufficient to qualify them as an expert on the subject to which the testimony relates.” Having reviewed her curriculum vitae and qualifications as a Psychiatric Nurse expert, the Court finds Rounds qualified to testify as to the standard of care for facilities providing psychiatric nursing services. Further, Plaintiff does not substantively brief her individual evidentiary objections to the declaration and appears to have repeated the same objections to each regardless of the statement’s content.

 

Defendant’s evidentiary objections to the declarations of David Rudnick and Gary Mittelberg are OVERRULED except as noted below. Defendant does not substantively brief their individual evidentiary objections to the declarations and appears to have repeated the same objections to each regardless of the statement’s content.  For example, Defendant objects as the declaration lacks foundation and calls for speculation; however, pages 2 and 3 of the declaration set forth an extensive list of the foundation upon which Dr. Rudnick relied.  RUDNICK SUSTAINED OBJECTIONS: Numbers 6 (Improper Expert Opinion), and 9 (Speculation).  MITTELBERG SUSTAINED OBJECTIONS: Number 27 (Speculation)

 

JUDICIAL NOTICE:

 

Plaintiff requests the Court take judicial notice of a jury verdict rendered in the case Gerard v. BHC Alhambra Hospital, Inc. LASC Case No. SC110387. Plaintiff does not substantively brief why notice should be taken and the Court declines the request.

 

ANALYSIS:

 

I.                LEGAL STANDARD

 

The function of a motion for summary judgment or adjudication is to allow a determination as to whether an opposing party cannot show evidentiary support for a pleading or claim and to enable an order of summary dismissal without the need for trial. (Aguilar v. Atlantic Richfield Co.¿(2001) 25 Cal.4th 826, 843.) C.C.P.¿§ 437c(c) “requires the trial judge to grant summary judgment if all the evidence submitted, and ‘all inferences reasonably deducible from the evidence’ and uncontradicted by other inferences or evidence, show that there is no triable issue as to¿any material fact and that the moving party is entitled to judgment as a matter of law.”¿ (Adler v. Manor Healthcare Corp. (1992) 7 Cal.App.4th 1110, 1119.)¿ “The function of the pleadings in a motion for summary judgment is to delimit the scope of the issues; the function of the affidavits or declarations is to disclose whether there is any triable issue of fact within the issues delimited by the pleadings.”¿ (Juge¿v. County of Sacramento¿(1993) 12 Cal.App.4th 59, 67, citing¿FPI Development, Inc. v. Nakashima¿(1991) 231 Cal.App.3d 367, 381-382.)¿ 

¿ 

As to each claim as framed by the complaint, the defendant moving for summary judgment must satisfy the initial burden of proof by presenting facts to negate an essential element, or to establish a defense. (C.C.P.¿§437c(p)(2);¿Scalf v. D. B. Log Homes, Inc.¿(2005) 128 Cal.App.4th 1510, 1520.) Courts “liberally construe the evidence in support of the party opposing summary judgment and resolve doubts concerning the evidence in favor of that party.” (Dore v. Arnold Worldwide, Inc.¿(2006) 39 Cal.4th 384, 389.)¿ 

¿ 

Once the defendant has met that burden, the burden shifts to the plaintiff to show that a triable issue of one or more material facts exists as to that cause of action or a defense thereto. To establish a triable issue of material fact, the party opposing the motion must produce substantial responsive evidence. (Sangster v.¿Paetkau¿(1998) 68 Cal.App.4th 151, 166.)¿ 

 

II.              MERITS

 

Background

 

Plaintiff was admitted to Defendant’s facility on May 17, 2020. (Mot. Exh. 1, p.1.) Upon admission Plaintiff was examined by Dr. Leonard Jones (“Jones”). (Id.) Jones noted that Plaintiff was “very psychotic, hyperreligious and tangential” and that Plaintiff was not eating or sleeping. (Id.) Jones noted that Plaintiff was admitted to Defendant’s facility on a 5150-hold as “gravely disabled” and estimated her stay would be three to five days. (Id. at p.2.) Jones issued Physician Admissions Orders for Plaintiff prescribing Ativan, Restoril, and later Zyprexa. (Id. at p. 91-92.)

 

TPP was admitted to Defendant’s facility on May 9, 2023 on a 5150-hold secondary to being a danger to others. (Mot. Exh. 2, p. 8-10.) TPP was placed on hold after he was evaluated for hearing voices, threatening to kill his brother, and threatening to burn down his house. (Id.) TPP was evaluated by Dr. Wakelin McNeel (“McNeel”) on May 10, 2023, who noted TPP was not taking his usually prescribed medication. (Id.) McNeel estimated TPP’s stay at Defendant’s facility to be between three and seven days. (Id.)

 

On May 10, 2023, TPP was observed by a housekeeper to have pulled the blanket off his roommate and punched the roommate in the face. (Opp. Exh. C, p. 17.) TPP was then determined to be a high risk of injury to others and transferred to a secluded unit known as the “Open Time Out” (“OTO”) room. (Id.) McNeel ordered an emergency treatment plan which directed that TPP be encouraged seek out staff if he was feeling agitated. (Id. at p. 47.) TPP was transferred out of the OTO on May 12, 2023. (Id.) TPP was ordered to be observed every 15 minutes by McNeel. (Mot. Exh. 2, p.74.) TPP remained on 15-minute observation the entirety of his stay at Defendant’s facility. (Id. p. 273-297.)

 

At around 3:00 a.m. on May 20, 2023, TPP left his room and entered Plaintiff’s room uninhibited. (Oppo. Exh. C, p. 177.) Immediately prior to the incident, TPP was observed to be pacing and unable to sleep. Plaintiff was asleep at the time when TPP began to strike Plaintiff in the face. (Mot. Exh. 1, p. 69.) Defendant’s staff responded to the incident and separated TPP from Plaintiff. (Id.) Plaintiff sustained serious injury and was ordered to the emergency room. (Id.) TPP was escorted back to his room by staff where he attempted to hit his roommate and was required to be physically restrained before medication was administered. (Oppo. Exh. C, p. 177.)

 

Standard of Care

 

Defendant first argues that summary judgment must be granted because there is no triable issue of material fact as to whether its staff upheld a standard of care.

 

“The elements of a cause of action for medical malpractice are: (1) a duty to use such skill, prudence, and diligence as other members of the profession commonly possess and exercise; (2) a breach of the duty; (3) a proximate causal connection between the negligent conduct and the injury; and (4) resulting loss or damage.” (Chakalis v. Elevator Solutions, Inc. (2012) 205 Cal.App.4th 1557, 1571.)

 

The standard of care against which the acts of a physician are to be measured is a matter peculiarly within the knowledge of experts; it presents the basic issue in a malpractice action and can only be proved by their testimony. (Hanson v. Grode (1999) 76 Cal.App.4th 601.) When a defendant moves for summary judgment and supports his motion with expert declarations that his conduct fell within the community standard of care, he is entitled to summary judgment unless the plaintiff comes forward with conflicting expert evidence. (Munro v. Regents of University of California (1989) 215 Cal.App.3d 977, 984–985 [citations omitted].)

 

To this end, Defendant presents the declaration of registered nurse Denise K. Rounds (“Rounds”). Rounds has been a registered nurse in the state of California since 1976 and has previously served as the Psychiatric Nurse Expert for the California Board of Registered Nursing. (Rounds Decl. ¶ 1.) Rounds states that the Lanterman-Petris-Short Act (“LPS Act”) bars Defendant’s staff from rendering treatment to mental health patients which is not expressly ordered by a physician. (Rounds Decl. ¶ 11(b).) Rounds cites to Welf. and Inst. Code § 5325.1 which provides in relevant part:

 

“Treatment should be provided in ways that are the least restrictive of the personal liberty of the individual. . . (c) A right to be free from harm, including unnecessary or excessive physical restraint, isolation, medication, abuse, or neglect . . .”

 

Rounds states that the only exception to the above provision is circumstances in which staff are confronted with a patient engaging in violent or self-destructive behavior. (Round Decl. ¶ 11(b).) Rounds states that because of this restriction, the applicable standard of care for a psychiatric nursing staff is limited to whether the staff appropriately implemented the attending physician’s orders. (Rounds Decl. ¶ 11(c).)

 

Rounds states that once TPP was released from OTO on May 12, Defendant’s staff had no basis to place TPP under further restraint or seclusion for lack of physician order. (Rounds Decl. ¶ 11(c).) Rounds further states that McNeel noted a positive reception to medications in TPP and noted no further violent behavior. (Id.) Rounds states that Defendant’s staff adhered to the standard of care by completing the physician ordered 15-minute checks throughout TPP’s stay at the facility. (Rounds Decl. ¶ 11(d).) Rounds further attests that TPP’s behavior immediately prior to the incident, where TPP was pacing and appeared agitated, was not cause for Defendant’s staff to restrain or seclude TPP. (Rounds Decl. ¶ 11(e).) Rounds further states that Defendant’s staff met the standard of care immediately after the incident by contacting the on-call physician. (Rounds Decl. ¶ 11(f).)

 

Rounds states that there is a pervasive risk of these sorts of incidents by virtue of Defendant’s care for a high volume of 5150-hold patients. (Rounds Decl. ¶ 11(h).) Rounds states that there was no evidence of understaffing and that Defendant’s staff on duty were all within sight range of the hallway. (Rounds Decl. ¶ 11(k).) Rounds states that there is also no evidence to suggest that Defendant’s staff improperly administered Zyprexa to Plaintiff, which would have resulted in her increased sleep and decreased reaction time. (Rounds Decl. ¶ 11(m).) Rounds lastly states that there is no evidence in her review that Defendant’s staff was unfit to carry out their jobs and that the staff acted only on physicians’ orders. (Rounds Decl. ¶ 11(n).)

 

Plaintiff argues that she has placed at issue the standard of care by virtue of presenting conflicting expert evidence. Plaintiff argues that Defendant fell below the standard of care in failing to evaluate and implement appropriate precautionary measures which would have prevented this incident.

 

Defendant presents the declaration of Dr. David Rudnick, who is Board Certified in Psychiatry. (Rudnick Decl. ¶ 2.)  Rudnick states that based upon his review of the records, Defendant’s behavior fell below the standard of care. Rudnick states that Defendant was aware that TPP has a history of psychosis and was expressing homicidal ideation before arriving at the facility. (Rudnick Decl. ¶ 9.) Rudnick states that despite “assault precautions” being designated for TPP, Defendant placed him on 15-minute checks, which constitutes the lowest level of surveillance. (Rudnick Decl. ¶ 10.) Rudnick states that Nicholas Duran (“Duran”), the nurse in charge of conducting the surveillance checks, stated the requirements for patients on “assault precautions” to be minimal. (Id.) Duran testified he was only required to give “assault precaution” patients medication and offer that they sit in the day room if they appeared unable to sleep. (Id.)

 

Rudnick further states that Defendant’s staff were aware for three hours prior to the attack that TPP was pacing and appeared agitated. (Id.) Rudnick states that despite this behavior, TPP was allowed to enter Plaintiff’s room unobserved by any of Defendant’s staff. (Id.) Rudnick also states that the standard of care was violated when Duran abandoned his hall monitor post to deliver documents to the charge nurse while the other staff were away on their meal break. (Id.) Rudnick states the violation continued when Defendant’s staff immediately placed TPP back into a room with another patient, despite his just having inflicted violence on Plaintiff. (Id.) Rudnick concludes that Defendant failed to provide elementary safety measures to protect patients from these sorts of incidents. Rudnick states that not ordering additional interventions to be implemented for patients with “assault precautions” is grossly insufficient. (Rudnick Decl. ¶12.)

 

Defendant also submits the declaration of Registered Psychiatric Nurse, Gary Mittelberg (“Mittelberg”). Mittelberg also states that Defendant violated the standard of care by placing TPP on the lowest possible surveillance despite the knowledge of his violent tendencies. (Mittelberg Decl. ¶ 8.) Mittelberg states Defendant’s “assault precautions” were inadequate to keep patients safe. (Mittelberg Decl. ¶ 9.) Mittelberg also states that Duran’s leaving his post without any available substitute indicates Defendant was understaffed to handle its patient population. (Mittelberg Decl. ¶ 11.) Mittelberg concludes that Defendant failed to protect its patients from TPP by continuously housing him with other patients and failing to supervise him more closely. (Mittelberg Decl. ¶ 12.)

 

The Court finds Plaintiff has provided sufficient expert testimony in contravention of Defendant’s own expert. “The trial court's gatekeeping role does not involve choosing between competing expert opinions…  The trial court's preliminary determination whether the expert opinion is founded on sound logic is not a decision on its persuasiveness. The court must not weigh an opinion's probative value or substitute its own opinion for the expert's opinion.” (Garrett v. Howmedica Osteonics Corp. (2013) 214 Cal.App.4th 173, 186.) A trial court may not “weigh competing expert opinions, evaluate their credibility, and pick a winner...” (Menges v. Department of Transportation (2020) 59 Cal.App.5th 13, 37.)

 

Defendant argues that Plaintiff’s declarations do not serve to dispute Defendant’s adherence to the standard of care. Defendant states neither the Rudnick nor the Mittelberg declarations speak to the prohibition of increased levels of observation created by the LPS Act. The Court finds this argument unpersuasive. The language cited by Defendant in the LPS act states that treatment “should” be provided in ways that are least restrictive of the personal liberty of the individual. Defendant does not endeavor to explain what these methods are or how this statutory directive is usually realized in the field of psychiatric nursing. The very nature of providing care for someone on a 5150-hold is restrictive of personal liberty. Welf. and Inst. Code § 5325.1 (c) states that it is the intent of the legislature that persons with mental illness have the right to be free from “unnecessary or excessive physical restraint”. This implies that some level of restraint is occasionally required in providing care to the mentally ill. Defendant cannot use this code section to defeat Plaintiff’s argument that the amount of supervision was insufficient, when the code section implicitly acknowledges some level of restraint is necessary. It cannot be that any action not directly ordered by an attending psychiatrist is a restriction on physical liberty.

 

Further, Plaintiff’s experts state Defendant’s protocol to implement the “assault precautions,” which were explicitly ordered by McNeel, were below the standard of care. Both Rudnick and Mittelberg attest that Defendant’s staff failed to properly implement the physicians orders. It is the contention of Plaintiff’s experts that Defendant’s procedures for handling “assault precaution” patients were woefully inadequate, especially in light of TPP’s prior violent outbursts. Further, both experts state that Duran was stationed as a hallway monitor and abandoned his post without replacement. This suggests either negligence on Duran’s part or that Defendant did not have enough staff on hand to properly implement the physician’s orders.

 

Both parties have presented conflicting expert testimony as to the standard of care in this case. As such, the Court finds Plaintiff has met her burden to show a triable issue of fact. Accordingly, the motion for summary judgment is DENIED; however, the Court will address the motion for summary adjudication.

 

Dependent Adult Claim

 

Case law is clear that neglect, within the meaning of Welf. and Inst. Code § 15610.57, covers an area of misconduct distinct from professional negligence.¿ (Covenant Care, Inc. v. Superior Court¿(2004) 32 Cal.4th 771, 783.)¿ “As used in the Act, neglect refers not to the substandard performance of medical services but, rather, to the failure of those responsible for attending to the basic needs and comforts of elderly or dependent adults, regardless of their professional standing, to carry out their custodial obligations.”¿ (Id. [citations and quotations omitted].)¿¿¿ 

 

“The degree of neglect that will support a claim for elder abuse is the failure to provide medical care, not the undertaking of medical services.” (Worsham v. O’Connor Hospital (2014) 226 Cal.App.4th 331, 336.) The act does not apply to simple or gross negligence by health care providers. (Id.) Rather, to obtain the enhanced remedies provided for under the Act, Plaintiff must show “by clear and convincing evidence that defendant is guilty of something more than negligence; he or she must show reckless, oppressive, fraudulent, or malicious conduct.” (Delaney v. Baker, 20 Cal. 4th 23, 31.) “Recklessness, unlike negligence, involves more than 'inadvertence, incompetence, unskillfulness, or a failure to take precautions' but rather rises to the level of a ‘conscious choice of a course of action … with knowledge of the serious danger to others involved in it.’” (Worsham supra, 226 Cal.App.4th at 337.)

 

Defendant first argues that Plaintiff’s claim fails as a matter of law because Welf. And Inst. Code § 15610.57 applies only to actions which derive the dependent adult of their basic needs. The Court finds this argument unpersuasive. Welf. And Inst. Code § 15610.57 (b)(3) defines “neglect” as including failure to protect from health and safety hazards. Here, Plaintiff is alleging Defendant failed to implement safety protocols which would have prevented her assault by TPP.

 

Defendant further argues that the supervision of TPP is irrelevant to whether Plaintiff was neglected within the meaning of the statute. The Court again is unpersuaded. Defendant’s duty to adequately safeguard its patient population from violent patients is relevant to its care of all patients, not just the patients being supervised. The fact that Defendant did nothing directly to Plaintiff does not disqualify her Dependent Adult Abuse claim. 

 

Defendant lastly argues that no triable issue of fact exists as to whether Defendant acted with recklessness, fraud, malice, or oppression. Defendant states that the failure of its staff to notice TPP entering Plaintiff’s room is at most the result of simple negligence.

 

In Carter the California Court of Appeals discussed situations in which care facilities had (1) failed to provide a man suffering from Parkinson’s disease sufficient food and water and necessary medication and left him unattended for long periods of time, (2) left a woman with a broken ankle lying unattended for long periods of time resulting pressure ulcers, and (3) an elderly man was abused beaten, and unlawfully restrained. (Carter v. Prime Healthcare Paradise Valley LLC (2011) 198 Cal.App.4th 396, 406.) While these examples are not exhaustive, they are illustrative of the types of transgression which are usually qualified as dependent adult abuse. The thread running through each of these examples is a pattern of prolonged failure to provide medical treatment, which is precisely the type of behavior contemplated by § 15675.

 

Here, the Court finds there is no “clear and convincing” evidence of dependent adult neglect. Plaintiff has presented two declarations that state the behavior of Defendant’s staff is indicative of Defendant’s insufficient protocol for handling violent patients. However, Plaintiff has not presented sufficient evidence to show that the conduct is anything beyond a case of simple negligence.  Both of Plaintiff’s declarations testify to a number of ways in Defendant’s protocol could be found inadequate, including:

 

·       The fact that Duran and other staff were only required to offer medication to agitated patients on “assault protocol”.

·       The fact that Duran left his hall monitor post with no substitute.

·       The fact that staff routinely placed TPP in close proximity to other patients despite knowledge that he was violent, including directly after he attacked Plaintiff.

 

Plaintiff’s claims that Defendant’s protocol was ineffective all reveal that some level or precaution was taken, or that some treatment was administered. Plaintiff does not allege that Defendant had no safeguards in place. It is clear from Plaintiff’s submissions that hall monitors were on guard the evening of the incident, even if they inappropriately left their post to deliver paperwork. Plaintiff’s submissions also show that checks were being completed by nurses on 15-minute intervals, showing that some level of precaution was being taken. In so far as the removal of TPP to a room with other patients after the attack, the Court finds this allegation more indicative of individualized poor decision making by the nursing staff than any established protocol of Defendant. In short, the conduct alleged by Plaintiff stands at odds with the conduct typically categorized as dependent adult abuse. Plaintiff does not allege protocols were not in place t to safeguard patients, she alleges the protocols that were in place were either inadequate in this specific instance or were ignored by Defendants’ staff. These allegations speak more to negligence than to dependent adult abuse. Based on the evidence presented, the Court finds the Plaintiff cannot show by clear and convincing evidence that Defendant’s conduct would rise to a level of Dependent Adult abuse. 

 

The Court acknowledges that less egregious behavior has been found in certain cases to become egregious when it is symptomatic of a scheme to deprive patients of care. In Fenimore¿v. Regents of University of California¿(2016) 245 Cal.App.4th 1339, the California Appellate Court determined that allegations that a hospital engaged in a pattern and practice of understaffing and undertraining its staff to cut costs, which foreseeably resulted in the abuse and neglect of its residents, were sufficient to state a cause of action under the Elder/Dependent Abuse Act. The Fenimore court found that:

 

Worsham’s determination that understaffing constitutes no more than negligence may be true,¿absent¿further allegations showing recklessness. But the Fenimores have alleged more than a simple understaffing here. The FAC identified the staffing regulation the Hospital allegedly violated and suggested a knowing pattern of violating it constituted recklessness. A jury may see knowingly flouting staffing regulations as part of a pattern and practice to cut costs, thereby endangering the facility’s elderly and dependent patients, as qualitatively different than simple negligence”

 

(Fenimore supra, 245 Cal.App.4th. at 1350.)

 

The Fenimore court concluded “Recklessness may be inferred when the neglect recurs in a significant pattern.” (Id.) However, the opinion in Fenimore does not describe what sort of pattern or practice would suffice to infer recklessness.  Although it is procedurally distinguishable from this case, in that it concerned pleading requirements and not the existence of a triable material fact, the Court finds the logic in Fenimore instructive. Fenimore found allegations of a corporate directive, i.e., understaffing, were sufficient to support a dependent adult abuse claim. Here, the is insufficient evidence to support a claim of understaffing.

 

Unlike in Fenimore, the evidence here does not show that Plaintiff’s injury resulted from systematic understaffing. The failure to notice TPP enter Plaintiff’s room appears at best to be the result of a staff member abandoning his post at an inopportune moment. Plaintiff submits insufficient evidence that the number of staff present the night of the incident was inadequat, much less that the number of staff usually assigned to monitor patients was routinely insufficient. Plaintiff presents no evidence of what adequate staffing looks like at an acute psychiatric facility or any other evidence to suggest that Defendant’s staffing was insufficient. In short, Plaintiff’s statement that Defendant was understaffed is at best speculative and cannot support a dependent adult abuse claim.

 

Based on the evidence presented, the Court finds the Plaintiff cannot show by clear and convincing evidence that Defendant’s conduct would rise to a level of Dependent Adult Abuse. 

 

To the extent that Plaintiff argues the “clear and convincing evidence” standard is misapplied, the Court finds this argument at odds with the reasoning in Delaney. The Delaney court explained:

 

if the neglect is “reckless[],” or done with “oppression, fraud or malice,” then the action falls within the scope of section 15657 and as such cannot be considered simply “based on . . . professional negligence” within the meaning of section 15657.2. The use of such language in section 15657, and the explicit exclusion of “professional negligence” in section 15657.2, make clear the Elder Abuse Act’s goal was to provide heightened remedies for, as stated in the legislative history, “acts of egregious abuse” against elder and dependent adults while allowing acts of negligence in the rendition of medical services to elder and dependent adults to be governed by laws specifically applicable to such negligence.

 

(Delaney supra, 20 Cal. 4th at 35 quoting Sen. 3d reading analysis, Sen. Bill No. 679.)

 

The Delaney court continuedThat only these egregious acts were intended to be sanctioned under section 15657 is further underscored by the fact that the statute requires liability to be proved by a heightened “clear and convincing evidence standard.” (Id.)

 

The idea that a cause of action under § 15657 is somehow sustainable without a claim for heightened remedies does not stand to reason. The legislative purpose of § 15657 is clear that the intended end result of a claim brought under the statute is to achieve heightened remedies which would not be obtainable under medical negligence claims. It cannot be that Plaintiff’ cause of action can survive even though its ultimate goal, enhanced remedies under § 15657 have been thwarted. To the extent that Plaintiff can maintain a cause of action against Defendant for its omissions, the law is clear that cause of action is founded in medical negligence and not elder abuse.

 

In short, the evidence indicates that while Defendants’ conduct may constitute simple negligence, it does not arise to a level contemplated by Fenimore. Based on the evidence presented, the Court finds the Plaintiff cannot show by clear and convincing evidence that Defendant’s conduct would rise to a level of Dependent Adult abuse. (Carter supra, 198 Cal. App. 4th at 407, 409.) Further, case law is clear that in the absence of “clear and convincing” evidence Plaintiff’s cause of action cannot survive, regardless of the extent of remedies sought Accordingly, the motion for summary adjudication of Plaintiff’s cause of action for Dependent Adult Abuse is GRANTED.

 

Willful Misconduct

 

Defendant argues that Willful Misconduct is not a separate cause of action. Indeed, willful misconduct is not a separate tort, but simply an aggravated form of negligence, differing in quality rather than degree from ordinary lack of care. (Berkley v. Dowds (2007) 152 Cal.App.4th 518, 526.) Regardless, the Court notes this argument does not speak to the summary judgment standard. If Defendant wished to have this cause of action removed as duplicative, the more appropriate avenue would have been a demurrer or motion to strike. Nonetheless, given the Court is granting the summary adjudication as to the second cause of action, the Cour will evaluate this cause of action similarly given the argument that it is duplicative. 

 

“Three essential elements must be present to raise a negligent act to the level of wilful [sic] misconduct: (1) actual or constructive knowledge of the peril to be apprehended, (2) actual or constructive knowledge that injury is a probable, as opposed to a possible, result of the danger, and (3) conscious failure to act to avoid the peril.” (Bains v. Western Pacific R. Co. (1976) 56 Cal.App.3d 902, 906 [internal quotations marks omitted].)

 

Plaintiff in the Complaint argues that BHC acted intentionally or with reckless disregard for Plaintiff’s safety, and that BHC knew or should have known of the high probability of injury or death from failing to adhere to their duties.   The Court finds that this allegation is simply not supported by the evidence.   As discussed above, while there may be an argument for simple negligence there simply is insufficient evidence to support a claim for willful action and/or recklessness disregard for a risk with a high probability of injury or death for a breach of a duty.  Further allegations in the Complaint of unfit employees or despicable conduct are not supported by the evidence.

 

As to this cause of action, the Court finds there is not a triable issue of fact as to whether Defendant knew of the peril presented by TPP and consciously declined to prevent it. As such, the summary adjudication of this cause of action is GRANTED.

 

Punitive Damages

 

BHC argues that Plaintiff did not comply with C.C.P. 425.13 which mandates Court approval before punitive damages may be included in a complaint.  The Plaintiff has never sought this leave from the Court, and furthermore the evidence does not show a substantial probability Plaintiff will prevail on the claim pursuant to Civil Code 3294.  C.C.P. §437c(f).  As such, the motion for summary adjudication for punitive damages is GRANTED.

 

RULING:

 

In the event a party requests a signed order or the court in its discretion elects to sign a formal order, the following form will be either electronically signed or signed in hard copy and entered into the court’s records.

 

ORDER

 

BHC Alhambra Hospital’s Motion for Summary Judgment came on regularly for hearing on December 18, 2023, with appearances/submissions as noted in the minute order for said hearing.  The Court having heard argument took the matter under submission and now rules as follows:

 

DEFENDANT’S MOTION FOR SUMMARY JUDGMENT IS DENIED.

 

DEFENDANT’S MOTIONS FOR SUMMARY ADJUDICATION IS GRANTED AS TO THE ELDER NEGLECT CAUSE OF ACTION, WILLFUL MISCONDUCT AND PUNITIVE DAMAGES AND IS DENIED AS TO PROFESSIONAL NEGLIGENCE.

 

CLERK TO GIVE NOTICE.

 

IT IS SO ORDERED.

 

DATE:  January 8, 2024                              

_______________________________

                                                                        F.M. TAVELMAN, Judge

                                                                        Superior Court of California

County of Los Angeles

 

 

LOS ANGELES SUPERIOR COURT

NORTH CENTRAL DISTRICT - BURBANK

DEPARTMENT A

 

RULING ON SUBMITTED MATTER

JANUARY 8, 2024

MOTION FOR SUMMARY JUDGMENT

WAKELIN MCNEEL, M.D.

Los Angeles Superior Court Case # 21STCV18294

 

MP:    Wakelin McNeel, M.D. (Defendant)

RP:     Olga Zharovskaya (Plaintiff)

 

NOTICE:  For convenience of expedited access by counsel, the Court is posting this matter on the Tentative Ruling website; however, it is a Ruling on the Submitted Matter.

 

ALLEGATIONS:

 

On May 14, 2023, Olga Zharovskaya (“Plaintiff”) filed suit against BHC Alhambra Hospital (“BHC”) and Wakelin McNeel M.D. (“McNeel”) (collectively “Defendants”). Plaintiff alleges McNeel was negligent in his care and in the supervision of a third-party patient (“TPP”) who attacked Plaintiff while she was a patient at BHC’s hospital. The Complaint contains causes of action for (1) Professional Negligence, (2) Dependent Adult Abuse, and (3) Willful Misconduct.

 

McNeel now moves for summary judgment on grounds that no triable issue of fact exists as to whether his actions in caring for TPP fell below the standard of care. Plaintiff opposes and McNeel replies.

 

At the hearing, McNeel presented the argument that he has no duty toward Plaintiff by function of Civil Code § 43.92. McNeel also presented argument that Plaintiff’s expert declaration lacked the proper basis to refute McNeel’s expert declaration as to the standard of care. Plaintiff in turn argued that Civil Code § 43.92 does not apply as McNeel was not only a physiatrist with BHC, but also a medical director.  The Court took the matter under submission to further assess the arguments made at the hearing. Having heard argument and reviewed the matter, the Court now rules as follows:

 

EVIDENTIARY OBJECTIONS:

 

McNeel’s evidentiary objections to the declaration of Dr. David Rudnick are OVERRULED as to Nos. 1, 2, 3, 6, and 7.

 

McNeel’s objection No. 4 is OVERRULED except as to the statement that TPP was “admitted without the restrictions that would be prudent in such circumstances”, to which the objection is SUSTAINED.  

 

McNeel’s objection No. 5. is OVERRULED except as to the statement that TPP forcibly attempted to kiss a different patient, to which the objection is SUSTAINED. The Court sees no evidence in TPP’s medical records, or any other exhibit, which documents this incident.

 

ANALYSIS:

 

III.            LEGAL STANDARD

 

The function of a motion for summary judgment or adjudication is to allow a determination as to whether an opposing party cannot show evidentiary support for a pleading or claim and to enable an order of summary dismissal without the need for trial. (Aguilar v. Atlantic Richfield Co.¿(2001) 25 Cal.4th 826, 843.) C.C.P.¿§ 437c(c) “requires the trial judge to grant summary judgment if all the evidence submitted, and ‘all inferences reasonably deducible from the evidence’ and uncontradicted by other inferences or evidence, show that there is no triable issue as to¿any material fact and that the moving party is entitled to judgment as a matter of law.”¿ (Adler v. Manor Healthcare Corp. (1992) 7 Cal.App.4th 1110, 1119.)¿ “The function of the pleadings in a motion for summary judgment is to delimit the scope of the issues; the function of the affidavits or declarations is to disclose whether there is any triable issue of fact within the issues delimited by the pleadings.”¿ (Juge¿v. County of Sacramento¿(1993) 12 Cal.App.4th 59, 67, citing¿FPI Development, Inc. v. Nakashima¿(1991) 231 Cal.App.3d 367, 381-382.)¿ 

¿ 

As to each claim as framed by the complaint, the defendant moving for summary judgment must satisfy the initial burden of proof by presenting facts to negate an essential element, or to establish a defense. (C.C.P.¿§437c(p)(2);¿Scalf v. D. B. Log Homes, Inc.¿(2005) 128 Cal.App.4th 1510, 1520.) Courts “liberally construe the evidence in support of the party opposing summary judgment and resolve doubts concerning the evidence in favor of that party.” (Dore v. Arnold Worldwide, Inc.¿(2006) 39 Cal.4th 384, 389.)¿ 

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Once the defendant has met that burden, the burden shifts to the plaintiff to show that a triable issue of one or more material facts exists as to that cause of action or a defense thereto. To establish a triable issue of material fact, the party opposing the motion must produce substantial responsive evidence. (Sangster v.¿Paetkau¿(1998) 68 Cal.App.4th 151, 166.)¿ 

 

IV.           MERITS

 

Background

 

TPP was admitted to Defendant’s facility on May 9, 2023 on a 72 hour hold secondary to being a danger to others. (TPP Medical Records p.8.) TPP was placed on hold after he was evaluated for hearing voices, threatening to kill his brother, and threatening to burn down his house. (Id.) TPP was evaluated by Dr. Wakelin McNeel (“McNeel”) on May 10, 2023. (Id.) McNeel estimated TPP’s stay at Defendant’s facility to be between three and seven days. (Id.) McNeel’s diagnoses upon admission were psychotic disorder and unspecified versus chronic schizophrenia versus schizoaffective disorder. (Id.) TPP was subject to a patient risk assessment upon admittance. (Id. at p. 5-6.) TPP reportedly scored a one out of twelve for assault risk. (Id. at p. 38.)

 

On May 10, 2023, TPP was observed by a housekeeper to have pulled the blanket off his roommate and punched the roommate in the face. (TPP Medical Records at. p. 5, 56.) TPP was then determined to be a high risk of injury to others and transferred to a secluded unit known as “adult unit one” and prescribed Haldol, Ativan, and Benadryl. (Id.) McNeel ordered an emergency treatment plan which directed that TPP be encouraged seek out staff if he was feeling agitated. (Id. at p. 64.) TPP was ordered to be observed every 15 minutes by McNeel. (Id. at p.73.) TPP remained on 15-minute observation the entirety of his stay at Defendant’s facility. (Id. p. 273-297.)

 

At around 3:00 a.m. on May 20, 2023, TPP left his room and entered Plaintiff’s room uninhibited. (TPP Medical Records p. 177.) Immediately prior to the incident, TPP was observed to be pacing and unable to sleep. Plaintiff was asleep at the time when TPP began to strike Plaintiff in the face. (Id. at p. 56.) Defendant’s staff responded to the incident and separated TPP from Plaintiff. (Id. at p. 177) TPP was escorted back to his room by staff where he attempted to hit his roommate and was required to be physically restrained before medication was administered. (Id.)

 

Civil Code § 43.92

 

McNeel argues that summary judgment should be granted because he has no duty of care toward Plaintiff as a matter of law. McNeel argues the California legislature has specifically provided in Civil Code § 43.92 that no action for damages may be maintained against a psychiatrist who has failed to protect others from violence inflicted by a patient.

 

Civil Code § 49.32 provides:

 

There shall be no monetary liability on the part of, and no cause of action shall arise against, any person who is a psychotherapist as defined in section 1010 of the evidence code in failing to protect from a patient’s threatened violent behavior or failing to predict and protect from a patient’s violent behavior except if the patient has communicated to the psychotherapist a serious threat of physical violence against a reasonably identifiable victim or victims.

 

As noted by the California Court of Appeal in Regents of University of California v. Superior Court, Civil Code § 49.32 was enacted by the California Legislature in reaction to the ruling in Tarasoff v. Regents of University of California. (See Regents of University of California v. Superior Court (2018) 29 Cal.App.5th 890, 904.) The statute was not designed to overrule Tarasoff, so much as it was intended to balance the public policy of doctor/patient confidentiality with the need to safeguard the public. (Id. at 904.) The statute attempts to prioritize the need for confidentiality while allowing for disclosure under circumstances where preserving the safety of an endangered individual is certain. (Id.)  In presenting this argument to the Court, McNeel relies primarily on Ewing v. Goldstein and Calderon v. Glick. The Court finds that a brief analysis of these rulings would be beneficial to the determination of McNeel’s argument.

 

In Ewing v. Goldstein, the parents of a victim killed by a therapist’s patient sued the therapist for wrongful death based on the therapist’s alleged failure to warn of a threat. (See Ewing v. Goldstein Ewing v. Goldstein (2004) 120 Cal.App.4th 807, 811.) The victim in Ewing was dating the patient, and the victim’s father had called and warned the therapist of threats of violence against the plaintiff. (Id.) Much of the decision in Ewing centered around the nature of the communication from the victim’s father and whether it qualified as a “patient communication” within the meaning of Civil Code § 49.32. (Id.) The Court of Appeal determined that “patient communication” included the father’s communication from the therapist, reasoning that a requirement the communication came from the patient is not crucial to the statutory purpose of Civil Code § 49.32. (Id. at 818.) The court further reasoned that because the communication from the father would have qualified as privileged, it was statutorily consistent to find the communication qualified for purposes of Civil Code § 49.32. (Id.)

 

Ultimately, the Ewing Court found that summary judgment was inappropriate because there existed questions of fact as to whether the therapist believed his patient intended to kill or seriously injure the victim. (Id. at 822.) The court reasoned that a determination of whether a threat under Civil Code § 49.32 was “serious” required determining whether the therapist in question believed in the veracity of the threat. (Id. at 820.) The Ewing Court found that because the therapist treated the victim for years and had intimate knowledge of his mental illness, it was plausible the therapist could have perceived the patient as not being a threat to the victim despite this warning. (Id.) Such possibilities constituted a triable issue of fact as to the therapists knowledge of a “serious” threat to the victim. (Id.)

 

The Court of Appeals reaffirmed the holding of Ewing in Calderon v. Glick, although there it was determined that no duty to warn existed. (See Calderon v. Glick (2005) 131 Cal.App.4th 224.) In Calderon, plaintiffs alleged therapists had a duty to warn when a patient shot three members of his former girlfriend’s family. (Id. at 228.) The gunman expressed the belief to his therapists that his former girlfriend had purposefully transmitted human T-cell lymphotropic (“HLTV”) to him. (Id.) The plaintiffs in Calderon argued that summary judgment was inappropriate because a question o fact existed as to whether the treating therapists actually believed or predicted their patient posed a serious threat of physical harm to the former girlfriend or her family. (Id. at 232.) The Court determined the evidence showed there was never a communication of an intent to injure anyone to the therapists. The records showed that the therapists asked the patient at each meeting if he intended to inflict violence on anyone and the response was always in the negative. (Id.) Further, the record showed no communication from the former girlfriend or her family to the therapists similar to that in Ewing. (Id.)

 

Most recently, the California Court of Appeal addressed Civil Code § 49.32 in Regents of the University of California v. Superior Court. In Regents, the victim was attacked by a fellow student on the University of California Los Angeles campus. (Regents of University of California v. Superior Court (2018) 29 Cal.App.5th 890, 895.) The attacker had been experiencing auditory hallucinations and believed many on the UCLA campus were committing transgressions against him. (Id.) The attacker was in communication with many school officials and was ultimately diagnosed by a school psychologist as being possibly schizophrenic. (Id.) The portion of the opinion addressing the psychologist is brief compared to Ewing and Calderon. The Court of Appeal held that because there was no evidence the any threat was ever communicated to the psychologist, she was entitled to judgment under Civil Code § 49.32. 

 

Here, the Court acknowledges there are a number of factual differences from the case law addressing Civil Code § 49.32. The victims in Ewing, Calderon, and Regents are more tenuously connected to the therapists in those cases than McNeel is to Plaintiff. The case law deals with estranged lovers, family members, or total strangers. None of the cases directly contemplate a situation in which the victim and the attacker are both members of an acute psychiatric care facility.

 

The Court understands that the proximity of Plaintiff to TPP and McNeel would tend in reason to indicate that injury to Plaintiff was more foreseeable. Regardless, it is clear from Ewing that the question of foreseeability only arises after an exception to Civil Code § 49.32 has been found. Civil Code § 49.32 is specifically concerned with the duty a therapists owes to third parties to protect from harm. The single exception to Civil Code § 49.32 is essentially a two-part inquiry: (1) was there a communication to the therapist of an intent to harm a reasonably identifiable person and (2) did that communication cause a serious belief on the therapists behalf that harm was likely to occur. Here, there is no evidence of a communication that would trigger the exception to Civil Code § 49.32.

 

Plaintiff argues that McNeel’s note that TPP tended to attack people in their sleep is sufficient to find an exception. The Court disagrees. Civil Code § 49.32 explicitly requires the threat be directed to a reasonably identifiable victim. A general observation that TPP has attacked someone in their sleep before is not a communication of intent to injure in the future and does not concern a reasonably identifiable person. In short, there is no communication which would trigger the exception to Civil Code § 49.32.

 

Plaintiff also raises argument regarding McNeel’s capacity as medical director for BHC. Plaintiff argues that because McNeel serves as a medical director, his remains liable for his BHC’s failure to implement further assault precautions. Plaintiff submits that McNeel has served as medical director at BHC since 2011. (See Plaintiff’s Exh. I, McNeel Depo p. 32.) Plaintiff argues that McNeel remains liable because he plays a part in the procedural decision and policy making at BHC. In McNeel’s words his duties as the medical director are to “represent the department from the physician’s end”, “bring up any issues the medical staff have regarding policies or procedures”, and coordinate between the doctors and the hospital. (Id.) It is also clear from the deposition of McNeel that he is being compensated by BHC directly for his services as director. (Id. at 34.) As discussed during oral argument, Dr McNeel was not a treating physician for Plaintiff.  As such, he had no professional duty to her.  His duty was to the TPP, who was his patient.   McNeel only treated Plaintiff on an emergent basis after the TPP’s attack, and the allegations in the complaint do not address professional negligence related to that treatment.   Furthermore, Plaintiff presented insufficient evidence that there is a triable issue of material fact that McNeel’s position as a contract medical director for which he received 1099 income rather than employee W2 income, imposed a duty of care as related to any staffing issues. 

 

As to Elder Neglect and Willful Misconduct for which these causes of action are alleged against all defendants, the Court incorporates by reference the analysis and law from the granting of the Motion for Summary Adjudication in favor of BHC Alhambra.

 

In short, the Court finds that McNeel did not have a duty to protect Plaintiff from TPP. Civil Code § 49.32 is clear that liability cannot be imposed on McNeel for TPP’s actions absent communication of a serious threat to harm Plaintiff. As the evidence shows no such communication occurred, summary judgment must be granted in favor of McNeel.

 

Accordingly, McNeel’s motion for summary judgment is GRANTED.

 

RULING:

 

In a party requests a signed order or the court in its discretion elects to sign a formal order, the following form will be either electronically signed or signed in hard copy and entered into the court’s records.

 

ORDER

 

Wakelin McNeel M.D.’s Motion for Summary Judgment came on regularly for hearing on January 5, 2024 with appearances/submissions as noted in the minute order for said hearing, and the Court took the matter under submission and issues this revised ruling as follows:

 

DEFENDANT’S MOTION FOR SUMMARY JUDGMENT IS GRANTED.

 

CLERK TO GIVE NOTICE.

 

IT IS SO ORDERED.

 

DATE:  January 8, 2024                              

_______________________________

                                                                        F.M. TAVELMAN, Judge

                                                                        Superior Court of California

County of Los Angeles