Judge: John J. Kralik, Case: 24NNCV06452, Date: 2025-04-04 Tentative Ruling

Case Number: 24NNCV06452    Hearing Date: April 4, 2025    Dept: NCB

 

Superior Court of California

County of Los Angeles

North Central District

Department B

 

 

berjue shamirian, by and through her successor-in-interest, hamlet shamirian, et al.,

 

                        Plaintiffs,

            v.

 

ksm healthcare, inc. dba dreier’s nursing care center,

 

                        Defendant.

 

Case No.:  24NNCV06452

 

Hearing Date:  April 4, 2025

 

 [TENTATIVE] order RE:

demurrer; motion to strike

 

 

BACKGROUND

A.    Allegations

Plaintiff Berjue Shamirian (“Decedent”), by and through her successor-in-interest, Hamlet Shamirian, and Hamlet Shamirian (“Mr. Shamirian”) filed this elder abuse action against Defendant KSM Healthcare, Inc. dba Dreier’s Nursing Care Center (“Defendant”).  Plaintiffs allege that Decedent died on December 16, 2023, and that she is succeeded by her surviving son, Mr. Shamirian.  Plaintiffs allege that Decedent was a resident of Defendant’s facility and that Defendant was a “care custodian” of Decedent pursuant to the Welfare & Institutions Code.  Plaintiffs allege that Decedent was neglected by Defendant when Defendant failed to protect her from health and safety hazards, failed to provide her physical health needs, and failed to exercise the degree of care that a reasonable person in a like position would exercise.  (FAC, ¶21.) 

Specifically, Plaintiffs allege that Decedent was admitted to the facility on November 29, 2023 for skilled nursing and rehabilitation services after hospitalization at St. Joseph Medical Center for pneumonia and sepsis.  Plaintiffs allege that Defendant failed to create or develop a care plan to address her respiratory issues or risk of infection associated with her Foley catheter and history of sepsis.  On December 13, 2023, Decedent had breathing difficulty such that her catheter was removed and a physician ordered Decedent’s urinary output be monitored.  However, Plaintiffs allege that Defendant failed to conduct a pain and abdominal assessment prior to removing the catheter and failed to monitor intake/output of fluids.  On December 14, 2023, Decedent had not urinated for 8 hours but her provider was not notified for the critical changes.  Plaintiffs allege that Decedent was then found unresponsive and thereafter her provider was notified and she was transported to Providence St. Joseph Medical Center.  Decedent passed away on December 16, 2023 at the hospital, listing the cause of death as septic shock and urosepsis. 

The first amended complaint (“FAC”), filed February 4, 2025, alleges causes of action for: (1) elder abuse/neglect; (2) negligence/willful misconduct; (3) violation of residents’ rights; and (4) wrongful death.

B.     Motions on Calendar

On March 5, 2025, Defendant filed a demurrer and motion to strike portions of the FAC.  

On March 31, 2025, Plaintiff filed a combined opposition brief.

On March 28, 2025, Defendant filed reply papers.  

DISCUSSION RE DEMURRER

            Defendant demurs to the 1st, 3rd, and 4th causes of action for elder abuse/neglect, violation of residents’ rights, and wrongful death, respectively.

A.    1st cause of action for elder abuse/neglect

            Pursuant to Welfare & Institutions Code, § 15610.27, an “elder” is any person residing in California that is 65 year of age or older.  Abuse of an elder means: “(a) Physical abuse, neglect, financial abuse, abandonment, isolation, abduction, or other treatment with resulting physical harm or pain or mental suffering” or “(b) The deprivation by a care custodian of goods or services that are necessary to avoid physical harm or mental suffering.”  (Welf. & Inst. Code, § 15610.07.)  “Neglect” includes the negligent failure of any person having the care or custody of an elder to exercise the degree of care that a reasonable person in like position would exercise, including the failure to provide medical care or protect from health and safety hazards.  (Id., § 15610.57(a)-(b).)  The statutory definition of “neglect” does not speak to the undertaking of medical services, but the failure to provide medical care.  (Carter v. Prime Healthcare Paradise Valley, LLC (2011) 198 Cal.App.4th 396, 404.)

            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.)

Examples of conduct sufficiently egregious to warrant the award of enhanced remedies under the Elder Abuse Act include the following:

1) An 88-year-old woman with a broken ankle was frequently left lying in her own urine and feces for extended periods of time and she developed pressure ulcers on her ankles, feet and buttocks that exposed bone, despite persistent complaints to nursing staff, administration, and to a nursing home ombudsman.  (Delaney v. Baker (1999) 20 Cal.4th 23, 41.) 

2) A physician concealed the existence of a serious bedsore on a nursing home patient under his care, opposed her hospitalization where circumstances indicated it was medically necessary, and then abandoned the patient when she was dying.  (Mack v. Soung (2000) 80 Cal.App.4th 966, 973.)

3) A skilled nursing facility failed to provide an elderly man suffering from Parkinson’s disease with sufficient food and water and necessary medication, left him unattended and unassisted for long periods of time, left him in his own excrement so that ulcers exposing muscle and bone became infected; and misrepresented and failed to inform his children of his true condition.  (Covenant Care, Inc. v. Superior Court (2004) 32 Cal. 4th 771, 778.)

4) A skilled nursing facility failed to provide adequate pressure relief to a 76-year-old woman with severe pain of her left leg and identified as at high risk for developing pressure ulcers, dropped the patient, left her in filthy and unsanitary conditions,  and failed to provide her the proper diet, monitor food intake and assist her with eating.  (Country Villa Claremont Healthcare Center, Inc. v. Superior Court (2004) 120 Cal.App.4th 426, 430, 434-435.)

5) The staff of a nursing home failed to assist a 90-year-old, blind, and demented woman with eating, used physical and chemical restraints to punish the elder and prevent her from obtaining help, and physically and emotionally abused the elder by bruising her, withholding food and water, screaming at her, and threatening her.  (Benun v. Superior Court (2004) 123 Cal.App.4th 113, 116-117.)

6) A 78-year-old man admitted to a skilled nursing facility was abused, beaten, unlawfully restrained, and denied medical treatment.  (Smith v. Ben Bennett, Inc. (2005) 133 Cal.App.4th 1507, 1512.) 

7) A facility caring for a dependent adult with a known condition causing progressive dementia, requiring nutrition and hydration through a gastrostomy tube, and subjecting her to skin deterioration, ignored a medical care plan requiring the facility to check the dependent adult’s skin on a daily basis and failed to notify a physician when pressure ulcers and other skin lesions developed.  (Sababin v. Superior Court (2006) 144 Cal.App.4th 81, 83-87, 90.)

(Carter v. Prime Healthcare Paradise Valley LLC (2011) 198 Cal. App. 4th 396, 406-407.)

            In the 1st cause of action, Plaintiffs allege that Decedent was 88 years old and an “elder.”  (FAC, ¶64.)  They allege that Defendant, a business providing long-term care as a 24-hour health facility, engaged in acts and omissions that constituted neglect.  (FAC, ¶¶65-67.)  Paragraphs 64-70 provide the general law regarding elders and elder abuse/neglect, paragraphs 71-84 are regarding ratification, and paragraph 85 seeks punitive damages.  The 1st cause of action incorporates the prior allegations, which include the facts of the case (as summarized above).

            Reading the complaint as a whole, the Court finds that the allegations fail to rise to the level of particularity required to show elder abuse and/or neglect.  Plaintiffs essentially allege the standard and the accompanying “buzz” words, but alleging these words without factual support amounts to conclusory pleadings.  At most, Plaintiffs allege that Defendant failed to conduct a pain and abdominal assessment prior to removing her catheter or failed to document her fluid intake/output (FAC, ¶¶24-25), as well as generalized allegations of understaffing.  However, Plaintiffs have not alleged Defendant’s failure to provide medical services to Decedent (as opposed to Defendant’s undertaking of medical services since Defendant removed the catheter, had her admitted to the hospital, etc. and alleged negligence thereto).  

            In addition, the allegations for ratification are generalized and conclusory.  (FAC, ¶¶71-85.)  The FAC lacks allegations that notice was provided regarding Decedent’s allegedly substandard care at the facility, or that an agent/officer of the facility ratified Defendant’s conduct.  No persons are identified in the FAC (caretakers, physicians, or management personnel).

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

B.     3rd cause of action for violation of residents’ rights

Plaintiffs’ 3rd cause of action is based on Health & Safety Code §1430(b), which expressly authorizes a current or former resident or patient of a skilled nursing facility to bring a civil action against the licensee of a facility who violates any rights of the resident or patient as set forth in the Patient’s Bill of Rights in 22 C.C.R. § 72527, or any other right provided for by federal or state law or regulation.  This is a statutory claim and the pleadings must state with reasonable particularity the facts supporting the statutory elements of the violation.  (Khoury v. Maly's of California, Inc. (1993) 14 Cal. App. 4th 612, 619.)

The 3rd cause of action incorporates the prior allegations and then essentially provides a recitation of the law.  (FAC, ¶¶95-96, 98.)  Plaintiffs allege that Defendant was a licensee of a skilled nursing facility (id., ¶97), Decedent was a member of a group protected under the statute (id., ¶100), and that Defendant violated Decedent’s Patient’s Bill of Rights under the code (id., ¶101).  These general allegations that refer to unknown, prior portions of the pleadings do not state with reasonable particularity the facts supporting the statutory elements of the claimed violation of section 1430(b).  As a result, the pleadings are insufficient. 

The demurrer to the 3rd cause of action is sustained with leave to amend.

C.     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 allege:

Plaintiffs hereby incorporate the allegations asserted in the paragraphs above of this Complaint as though set forth at length below. Specifically, Ms. SHAMIRIAN was admitted to Providence St. Joseph Medical Center on December 14, 2023, with diagnoses of septic shock, multi-organ failure due to urinary and pulmonary infections, acute respiratory failure with pneumonia and bilateral pleural effusions, acute kidney injury with acute tubular necrosis, and atrial fibrillation with rapid ventricular response. Despite treatment, she tragically passed away on December 16, 2023, at Providence St. Joseph Medical Center. Ms. SHAMIRIAN’s death certificate lists the cause of death as septic shock and urosepsis as her cause of death.  Due to Defendants’ failure to create, develop, and initiate the appropriate care plans, the medical care necessary to meet her physical health needs was withheld. This medical care would include daily respiratory assessments and daily assessments for signs/symptoms of infection. The standard of care required the Defendants to monitor Ms. SHAMIRIAN for signs/symptoms of infection every shift. Had Defendants provided this care, Ms. SHAMIRIAN’s fatal infection would have been identified timely, allowing the physician to prescribe life-saving medical care and treatment. FACILITY also failed to monitor, measure, and record fluid intake and output for Ms. SHAMIRIAN who had an indwelling catheter, as required by her plan of care, the facility’s policies and procedures, and the standard of care. Had FACILITY performed the required intake and output monitoring, the nursing staff could have quickly identified issues like reduced or absent urine flow, prompting timely interventions. Patients with indwelling catheters are at high risk for urinary tract infections (UTIs), which can escalate to serious conditions like urosepsis. Monitoring urine for changes in color, clarity, or odor can help detect infections early. Defendants’ failure to monitor Ms. SHAMIRIAN’s urine output resulted in a critical delay in treatment for her infection, causing her to develop urosepsis. In sum, regular and accurate monitoring of urine intake and output for patients with indwelling catheters is essential for maintaining their health, preventing complications, and ensuring early intervention when issues arise. By neglecting this aspect of care, Defendant caused a severe and fatal outcome, as demonstrated by Ms. SHAMRIRIAN’s development of urosepsis. 

(FAC, ¶102.) 

Defendant argues that while Plaintiffs allege that Decedent passed away, the FAC fails to allege facts regarding how Defendant’s conduct ultimately caused Decedent’s death. 

While Plaintiffs have not alleged sufficient facts for elder abuse at this time, the allegations are sufficient to allege a wrongful death cause of action based on negligence.  Paragraph 102 sufficiently alleges facts that Defendant’s failure to implement an appropriate care plan, perform daily assessments, have prescriptions and treatment timely administered, etc. caused Decedent to undergo septic shock and organ failure.  As such, the Court will allow the cause of action to stand.

The demurrer to the 4th cause of action is overruled. 

DISCUSSION RE MOTION TO STRIKE

            Defendant moves to strike the allegations for attorney’s fees and costs and punitive damages with respect to the 1st cause of action, and attorney’s fees and costs with respect to the 3rd cause of action. 

            In light of the ruling to sustain the demurrer to the 1st and 3rd causes of action, the motion to strike is taken off-calendar as moot.

CONCLUSION AND ORDER

Defendant KSM Healthcare, Inc. dba Dreier’s Nursing Care Center’s demurrer is sustained with 20 days leave to amend as to the 1st and 3rd causes of action.  The demurrer is overruled as to the 4th cause of action.

Defendant shall provide notice of this order.

 

DATED: April 4, 2025                                                           ___________________________

                                                                                          John Kralik

                                                                                          Judge of the Superior Court