Judge: John J. Kralik, Case: 21STCV40177, Date: 2024-08-16 Tentative Ruling


Counsel who wish to submit on the tentative ruling may do so by emailing BURDeptB@lacourt.org

PLEASE WRITE THE CASE NUMBER AND PARTY YOU REPRESENT.  YOU MAY ONLY SUBMIT ON BEHALF OF THE PARTY YOU REPRESENT.  YOU MAY NOT SUBMIT ON BEHALF OF ANOTHER PARTY. Counsel are directed to cc all other counsel if you are submitting on the tentative ruling.

IF YOU HAVE QUESTIONS OR NEED CLARIFICATION ON THE TENTATIVE, YOU MUST APPEAR AND ADDRESS YOUR QUESTIONS TO THE COURT.

IF BOTH SIDES SUBMIT ON THE TENTATIVE RULING, THE TENTATIVE RULING THEN BECOMES THE ORDER OF THE COURT ON THE MOTION DATE AND NO APPEARANCES ARE NECESSARY.


THERE WILL BE NO RESPONSES TO ANY INQUIRIES SUBMITTED THROUGH THIS SITE.

Warning regarding electronic appearances
:    All software for remote or electronic appearances is subject to malfunction based on system weakness and human error, which can originate from any of the multiple parties participating each morning. The seamless operation of the Court’s electronic appearance software is dependent on numerous inconstant and fluctuating factors that may impact whether you, or other counsel or the Court itself can be heard in a particular case. Not all these factors are within the control of the courtroom staff. For example, at times, the system traps participants in electronic purgatories where they cannot be heard and where the courtroom staff is not aware of their presence. If you call the courtroom, please be respectful of the fact that a court hearing is going on, and that the courtroom staff is doing their best to use an imperfect system. If it is truly important to you to be heard, please show up to the courtroom in the normal way. Parking is free or reasonable in Burbank.


THANK YOU!





Case Number: 21STCV40177    Hearing Date: August 16, 2024    Dept: NCB

 

Superior Court of California

County of Los Angeles

North Central District

Department B

 

 

sandra martin, et al.,

 

                        Plaintiffs,

            v.

 

baj management, inc. dba Prospect manor,

 

                        Defendant.

 

Case No.:  21STCV40177

 

Trial Date:  August 16, 2024

 

 [TENTATIVE] ORDER RE:

demurrer; motion to strike

 

 

BACKGROUND

A.    Allegations

Plaintiffs Sandra Martin, Stanley Brown, Elizabeth Brown, and Charlotte Bland, as individuals and as successors and heirs (“Plaintiffs”) of Olive Brown (“Decedent”) allege that Decedent was a resident of Defendant Baj Management, Inc. dba Prospect Manor (“Defendant”).  Plaintiffs allege that in the midst of the coronavirus pandemic, Defendant intentionally concealed that several working staff members and residents had been exposed to the COVID-19 and failed to take steps to ensure that its staff members followed CDC guidelines to safeguard elderly and vulnerable residents. 

Plaintiffs allege that Decedent was a resident of Defendant’s nursing home and was generally in good health during the last year of her life with certain monitored medical conditions that were being well-managed and under control.  (Compl., ¶¶25-26.)  Plaintiffs allege that her pre-existing medical conditions required attention and care and any changes to her condition were to be reported to the attending physician.  (Id., ¶27.)  They allege that Defendant accepted responsibility to provide caretaking and custodian services.  (Id., ¶28.)  Plaintiffs allege that throughout 2020, Defendant failed to provide staff, employees, and residents with adequate personal protective equipment (“PPE”) for the COVID-19 outbreak; failed to properly instruct staff regarding proper protocol to protect residents; failed to adopt and implement effective procedures to instruct and warn visitors regarding the dangers of COVID-19; failed to post conspicuous signs to warn of the dangers and mandate PPE and other safety precautions; failed to provide/require visitors or staff the use of sanitizers or take temperatures; were understaffed such that Defendant was unable to effectively screen or prevent visitors on the premises; knowingly permitted staff to work at the facility despite contracting or exhibiting signs of COVID-19; and concealed or failed to warn residents about staff with COVID-19.  (Id., ¶¶32-39.)  Plaintiffs allege that due to Defendant’s failures as listed above, its failure to test staff and residents, and delay in implementing an effective policy for isolating carriers, Decedent was exposed to, contracted, and passed away due to COVID-19.  (Id., ¶¶40-43.)  They allege that on December 10, 2020, nurse Gloria informed Plaintiff Charlotte Bland that Decedent had tested positive for COVID-19 but was asymptomatic and was doing fine, and Bland contacted Dr. Marilynn Moore.  (Id., ¶¶46-47.)  Under Dr. Moore’s instructions, Decedent was transported to Huntington Hospital Emergency Room that same day, where her condition worsened and Decedent passed away on December 27, 2020 due to COVID-19.  (Id., ¶49.) 

The complaint, filed November 1, 2021, alleges causes of action for: (1) elder abuse; (2) willful misconduct; (3) negligence; and (4) wrongful death.

B.     Motions on Calendar

On May 9, 2024, Defendant filed a demurrer and motion to strike portions of the complaint.

On May 29, 2024, Plaintiffs filed opposition briefs.

On June 4, 2024, Defendant filed reply briefs.

REQUEST FOR JUDICIAL NOTICE

            Defendant requests judicial notice of Exhibits: (A) the complaint; (B) the CDC’s July 31, 2020 Public Health Guidance for Community-Related Exposure; (C) a CDC study published on January 7, 2021 entitled, “SARS-CoV-2 Transmission from People without COVID-19 Symptoms; (D) an October 6, 2020 California Department of Social Services PIN 20-37-ASC, notifying Residential Care Facilities for the Elderly of the latest staffing waivers in effect; and (E) a November 20, 2020 California Department of Social Services PIN 20-42-ASC, notifying Residential Care Facilities for the Elderly of the latest directives relating to the mitigation of COVID-19.  The request is granted.  (Evid. Code, § 452(c)-(d).) 

DISCUSSION RE DEMURRER

            Defendant demurs to each cause of action alleged in the complaint.

A.    1st cause of action for elder abuse

            A plaintiff must prove more than simple or even gross negligence in the provider’s care or custody of the elder or dependent adult.  (Carter v. Prime Healthcare Paradise Valley LLC (2011) 198 Cal.App.4th 396, 405.)  The plaintiff must prove by clear and convincing evidence that defendant was guilty of recklessness, oppression, fraud or malice in the commission of the neglect, which applies essentially the equivalent standard to support punitive damages.  (Id.; Welf. & Inst. Code, § 15657.)  The enhanced remedies are available only for acts of egregious abuse against elder or dependent adult.  (Carter, supra, 198 Cal.App.4th at 405.) “‘Recklessness’ refers to a subjective state of culpability greater than simple negligence, which has been described as ‘deliberate disregard’ of the ‘high degree of probability’ that an injury will occur” and rises to the level of a conscious choice of a course of action with knowledge of the serious danger to others involved in it.  (Delaney v. Baker (1999) 20 Cal.4th 23, 31-32.)  Unlike negligence, recklessness involves more than inadvertence, incompetence, unskillfulness, or a failure to take precautions.  (Id. at 31.)

            There are several factors that must be pled with particularity, including: (1) defendants had responsibility for meeting the basic needs of the elder or dependent adult, such as nutrition, hydration, hygiene or medical care; (2) defendants knew of conditions that made the elder or dependent adult unable to provide for his or her own basic needs; (3) defendants denied or withheld goods or services necessary to meet the elder or dependent adult’s basic needs, either with knowledge that injury was substantially certain to befall the elder or dependent adult (if the plaintiff alleges oppression, fraud or malice) or with conscious disregard of the high probability of such injury (if the plaintiff alleges recklessness); and (4) the neglect caused the elder or dependent adult to suffer physical harm, pain or mental suffering.  (Carter, supra, 198 Cal.App.4th at 406-407.)

            In the 1st cause of action, Plaintiffs allege that Decedent was an elderly person and Defendant had the care and custody of her during the relevant times.  (Compl., ¶¶56-57.)  Plaintiffs allege that Defendant failed to protect Decedent from health and safety hazards, thereby committing neglect.  (Id., ¶58.)  Plaintiffs allege that Decedent was intentionally or recklessly exposed to COVID-19 and not provided with PPE equipment needed to guard against the dangers faced from the transmission of COVID-19. (Id., ¶59.) 

            Upon review of the general factual allegations of the complaint and the allegations of the 1st cause of action, the Court finds that the 1st cause of action for elder abuse and neglect has not been adequately pled with the requisite specificity.  While Plaintiffs allege that Defendant failed to implement certain CDC standards, failed to post warning signs in the facility, and allowed staff and residents with COVID-19 to remain at the facility, the allegations at most rise to the level of negligence.  The allegations, taken together, do not rise to a showing of willful, intentional conduct, or reckless behavior on the part of Defendant; rather, at most, the allegations rise to a level of negligent conduct, which is not sufficient for a statutory elder abuse claim.

            The demurrer to the 1st cause of action is sustained with leave to amend.

B.     2nd cause of action for willful misconduct

A claim for willful misconduct is intentional wrongful conduct, done either with a knowledge that serious injury to another will probably result, or with a wanton and reckless disregard of the possible results.   (New v. Consolidated Rock Products Co. (1985) 171 Cal. App. 3d 681, 689-90.)  Willful misconduct is an aggravated form of negligence, differing in quality rather than degree from ordinary lack of care.  (Id.)  The usual meaning assigned to willful or reckless conduct is that the actor has intentionally done an act of an unreasonable character in disregard of a risk known to him or so obvious that he must be taken to have been aware of it, and so great as to make it highly probable that harm would follow.  (Id.)  Accordingly, three essential elements must be present to raise a negligent act to the level of willful 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.  (Id.)  Further, the tort’s pleading requirements are similar to negligence but stricter.  (Berkley v. Dowds (2007) 152 Cal.App.4th 518, 526.)

In the 2nd cause of action, Plaintiffs allege that Defendant knew or should have known of their failure to comply with the standard of care by lacking appropriate safety equipment and not employing reasonable custodial policies for isolating COVID-positive residents.  (Compl., ¶65.)  Plaintiffs allege that Defendant knew or should have known that the peril posed by its failure to comply with the standard of care exposed Decedent to a high probability of her death.  (Id., ¶66.)  Plaintiffs allege that Defendant failed to comply with certain duties.  (Id., ¶67, see ¶¶32-39.)  Plaintiffs allege that Defendant made certain financial and budgetary decisions to limit purchase of PPE, which resulted in exposure of COVID-19 to its residents including Decedent.  (Id., ¶68.) 

For the same reasons discussed above, the willful misconduct cause of action also fails to allege sufficient facts. The allegations are conclusory recitations of the elements and fail to rise to a showing that Defendant acted with intentionality, as such facts must be pleaded with a higher pleading standard than ordinary negligence.  Again, the Court finds that, at most, the facts alleged in this cause of action are indicative of negligence, but not necessarily willful conduct. 

The demurrer to the 2nd cause of action is sustained with leave to amend.

C.     3rd cause of action for negligence

The elements of a negligence cause of action are “duty, breach of duty, proximate cause, and damages.”  (Carlsen v. Koivumaki (2014) 227 Cal.App.4th 879, 892.) 

In the 3rd cause of action, Plaintiffs allege that Decedent was admitted as a resident of Defendant for approximately the last 20 years of her life.  (Compl., ¶73.)  They allege that Defendant owed her a duty of ordinary care to use the degree of care and skill that a reasonably prudent person and nursing home would owe.  (Id., ¶74.)  Plaintiffs allege that Defendant breached their duties by failing to implement policies, procedures, and safety measures necessary to prevent Decedent’s exposure to COVID-19 and by failing to provide appropriate treatment once she was infected by the virus.  (Id., ¶75.) 

Defendant argues that it is a residential care facility and not a skilled nursing facility, such that the duty and standard of care it would owe is that of a reasonably prudent residential care facility for the elderly, which is a different standard.  However, at the pleading stage, the Court takes the allegations of the complaint as true and Plaintiffs have alleged that Defendant is a nursing home, as opposed toa residential care facility.  Defendant may, at the summary judgment or trial stage, prove that it is not a nursing home and that it is instead a residential care facility and held to a different standard, but at the demurrer stage, the Court cannot accept Defendant’s extrinsic facts. 

The demurrer to the 3rd cause of action is overruled.   

D.    4th cause of action for wrongful death

The elements of a wrongful death cause of action are: (1) a wrongful act or neglect on the part of one or more persons that (2) causes (3) the death of another person.  (Nogart v. Upjohn Co. (1999) 21 Cal.4th 383, 390.)

In the 4th cause of action, Plaintiffs incorporate all prior allegations and allege that as a direct and proximate result, Decedent died and Plaintiffs are deprived of her care, comfort, and society.  (Compl., ¶¶77-78.) 

As Plaintiffs have alleged a viable cause of action for negligence, there are sufficient facts to allege a cause of action for wrongful death premised upon negligence.  As such, the demurrer to the 4th cause of action is overruled.

DISCUSSION RE MOTION TO STRIKE

            Defendant moves to strike allegations for enhanced remedies under the Elder Abuse Act, including attorney’s fees and punitive damages. 

            In light of the ruling on the demurrer to the 1st cause of action for elder abuse, the Court grants the motion to strike the allegations for enhanced remedies and the request attorney’s fees pursuant to the Elder Abuse Act.  Similarly, the allegations for punitive damages are generalized and conclusory, such that they do not rise to the level of particularity required for a request for punitive damages.  Plaintiffs should allege further facts supporting a showing of oppression, malice, and/or fraud to warrant a request for punitive damages. 

            The motion to strike is granted with leave to amend.

CONCLUSION AND ORDER

Defendant Baj Management, Inc. dba Prospect Manor’s demurrer to the 1st and 2nd causes of action in the complaint is sustained with 20 days leave to amend.  The demurrer to the 3rd and 4th causes of action is overruled. 

Defendant Baj Management, Inc. dba Prospect Manor’s motion to strike is granted with 20 days leave to amend.  

Defendant shall provide notice of this order. 

 

DATED: August 16, 2024                                                      ___________________________

                                                                                          John Kralik

                                                                                          Judge of the Superior Court