Judge: Lee W. Tsao, Case: 21STCV24995, Date: 2023-08-10 Tentative Ruling

Case Number: 21STCV24995    Hearing Date: August 10, 2023    Dept: C

FOX v. CERRITOS VISTA HEALTHCARE CENTER LLC

CASE NO.:  21STCV24995

HEARING:  08/10/23

 

#9

 

     I.        Defendant CERRITOS VISTA HEALTHCARE CENTER LLC’s Demurrer to Plaintiffs’ First Amended Complaint is OVERRULED.

 

    II.        Defendant CERRITOS VISTA HEALTHCARE CENTER LLC’s Motion to Strike Portions of Plaintiffs’ First Amended Complaint is DENIED.

 

Opposing Party to Give notice.

 

Defendant’s Request for Judicial Notice is GRANTED. (Cal. Ev. Code §452.)

 

This wrongful death/elder abuse action was filed by Plaintiffs MAUDE FOX, deceased, by and through her personal legal representative and successor in interest Deisree Fox; and DESIREE FOX, individually (collectively “Plaintiffs”).

 

On December 29, 2022, the operative First Amended Complaint (“FAC”) was filed.

 

Plaintiffs allege that “Decedent MAUDE was admitted to Defendant FACILITY in 2019 for skilled and custodial services to meet her care needs.” (FAC ¶40.) “Decedent MAUDE’s medical history made her susceptible to viral communicable diseases. [¶] Defendants knew or should have known, that prevention and care is especially important among nursing home residents such as Decedent MAUDE, who are more susceptible to respiratory infection/syndrome due to their age and medical conditions.” (FAC ¶44.) “Defendant FACILITY failed to provide adequate care to Decedent MAUDE and failed to effectively develop, implement, and modify care plans for her individualized care needs.” (FAC ¶45.) “On June 17, 2020, Decedent MAUDE tested positive for COVID-19. [¶] Over the next few days, Decedent MAUDE’s health continued to decline. She was diagnosed with pneumonia. [¶] Unsurprisingly, Decedent MAUDE’s health continued to deteriorate. Decedent MAUDE could not recover from her extreme respiratory infection/syndrome and other injuries and died on June 21, 2020.” (FAC ¶¶50-52.) 

 

Plaintiffs’ FAC asserts the following causes of action: (1) Elder Abuse and Neglect; (2) Violation of Patient Rights; (3) Negligence; and (4) Wrongful Death.

 

Defendant CERRITOS VISTA HEALTHCARE CENTER LLC (“Defendant”) argues that Plaintiffs’ action is preempted, and the demurrer should be sustained without leave to amend. Defendant also generally demurs to the first, second, third, and fourth causes of action.

 

Preemption

The PREP act states that “a covered person shall be immune from suit and liability under Federal and State law with respect to all claims for loss caused by, arising out of, relating to, or resulting from the administration to or the use by an individual of a covered countermeasure if a declaration under subsection (b) has been issued with respect to such countermeasure.” (42 U.S.C.A §247d-6d(a)(1).) “The immunity under paragraph (1) applies to any claim for loss that has a causal relationship with the administration to or use by an individual of a covered countermeasure, including a causal relationship with the design, development, clinical testing or investigation, manufacture, labeling, distribution, formulation, packaging, marketing, promotion, sale, purchase, donation, dispensing, prescribing, administration, licensing, or use of such countermeasure.” (42 U.S.C.A §247d-6d(a)(1)(B).)

 

In line with the 9th Circuit’s holding in Saldana v. Glenhaven Healthcare LLC (“Saldana”) (2022) 27 F.4th 679, 688, this Court finds that Plaintiffs’ claims herein are not preempted by the PREP Act. Saldana is factually analogous. In Saldana, the plaintiffs alleged that their decedent died from COVID-19 while residing at the defendant nursing home. The complaint alleged four state-law causes of action: elder abuse, willful misconduct, custodial negligence, and wrongful death.  The 9th Circuit determined that federal subject matter jurisdiction was not proper because Plaintiffs failed to demonstrate that the PREP Act is a complete preemption statute; that is, Congress intended the scope of the federal law to be so broad as to entirely replace any state-law claim.  (Saldana at 686, emphasis in original.)  Rather, “[t]he text of the statute shows that Congress intended a federal claim only for willful misconduct claims and not claims for negligence and recklessness.” (Id at 688.)  Moreover, simply because one of Plaintiffs’ claims may be preempted is different than finding that the federal statutory scheme is so comprehensive that it entirely supplants state law causes of action.  (Id, emphasis in original.)  Here, on analogous facts, Defendant’s preemption argument fails for the reasons set forth in Saldana. 

 

First Cause of Action – Elder Abuse

A cause of action under the Elder Abuse Act must be alleged with particularity.    (See Covenant Care, Inc. v. Superior Court (2004) 32 Cal.4th 771, 790.)   Acts that constitute mere professional negligence do not constitute elder abuse.  “In order to obtain the remedies available in section 15657, a plaintiff must demonstrate 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. The latter three categories involve "intentional," "willful," or "conscious" wrongdoing of a "despicable" or "injurious" nature.”  (Delaney v. Baker (1999) 20 Cal.4th 23, 31-32.)   “To recover the enhanced remedies available under the Elder Abuse Act from a health care provider, a plaintiff must prove more than simple or even gross negligence in the provider's care or custody of the elder.”  (See Carter v. Prime Healthcare Paradise Valley LLC (2011) 198 Cal.App.4th 396, 405.)  “‘[T]he legislature intended the Elder Abuse Act to sanction only egregious acts of misconduct distinct from professional negligence….” (Covenant Care, Inc. v. Superior Court (2004) 32 Cal.4th 771, 784.) In summary, to plead a cause of action for elder abuse under the Act based on neglect, a plaintiff must allege facts establishing that the defendant: “(1) had responsibility for meeting the basic needs of the elder or dependent adult,” “(2) knew of conditions that made the elder or dependent adult unable to provide for his or her own basic needs”; and “(3) 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…or with conscious disregard for the high probability of such injury….” (Carter v. Prime Healthcare Paradise Valley, LLC (2011) 198 Cal.App.4th 396, 405-407.) A plaintiff must also allege facts demonstrating that the neglect caused the elder or dependent adult to suffer physical harm, pain, or mental suffering such that the causal link between the neglect and injury is specifically alleged. (Id at 407.) Section 15610.63(a)(1) defines neglect in relevant part as follows: “The negligent failure of any person having the care or custody of an elder or dependent adult to exercise that degree of care that a reasonable person in a like position would exercise.” Subsection (b) provides specific examples of neglect, and states in relevant part: “Neglect includes… (3) [f]failure to protect from health and safety hazards.” To state an elder abuse claim, a plaintiff must allege facts showing that an officer, director, or managing agent of defendant was involved in the abuse, authorized the abuse, ratified the abuse or hired the person who did the abuse with advance knowledge of the persons unfitness and hired him with a conscious disregard of the rights and safety of others. (Welf. & Inst. Code §15657(c); Cal. Civ. Code §3294.) “[T]he Act does not apply unless the defendant health care provider had a substantial caretaking or custodial relationship, involving ongoing responsibility for one or more basic needs, with the elder patient.” (Winn v. Pioneer Medical Group, Inc. (2016) 63 Cal.4th 148, 152.) 

 

The demurrer to the first cause of action is OVERRULED.

 

Plaintiffs adequately allege the existence of a caretaking/custodial relationship. (FAC ¶20.) The FAC also adequately alleges that the Defendant wrongfully and knowingly withheld care from the Decedent for purposes of surviving demurrer. (See e.g., FAC ¶¶ 55, 58, 60-79.)

 

On demurrer, the Court is bound to accept Plaintiffs’ allegations and construe the allegations ‘liberally in favor of the pleader.’ (Ferrick v. Santa Clara University (2014) 231 Cal.App.4th 1337, 1341.) The arguments raised by Defendant raise factual determinations improperly resolved at this stage in the litigation.

 

Second Cause of Action – Violation of Patient Rights

“A current or former resident or patient of a skilled nursing facility…. or intermediate care facility…may bring a civil action against the licensee of a facility who violates any rights of the resident or patient as set forth int eh Patients Bill of Rights…or any other right provided for by federal or state law or regulation.” (Cal. Health and Safety Code §1430(b).)

 

Defendants’ demurrer to the second cause of action is OVERRULED. Plaintiff adequately alleges a claim for a Violation of Health and Safety Code §1430(b). (See FAC ¶89.)

 

Third Cause of Action – Negligence

A claim for professional medical negligence has three necessary elements: (1) negligence (standard of care); (2) harm; and (3) causation.

 

Defendant’s demurrer to the third cause of action is OVERRULED. Plaintiff has adequately alleged the elements of negligence. (See FAC ¶¶93-95.)

 

Fourth Cause of Action – Wrongful Death 

“The elements of a cause of action for wrongful death are a tort, such as negligence, and resulting death. [Citation.]” (Lopez v. City of Los Angeles (2011) 196 Cal.App.4th 675, 685.)

 

Plaintiffs have sufficiently alleged an underlying claim for elder abuse, and that Decedent’s death was caused by Defendant’s elder abuse and neglect. For pleading purposes, this is sufficient. The demurrer to this cause of action is OVERRULED.

 

Motion to Strike

A motion to strike lies either when (1) there is “irrelevant, false or improper matter inserted in any pleading”; or (2) to strike any pleading or part thereof “not drawn or filed in conformity with the laws of this state, a court rule or order of court.” (CCP §436.)

 

The motion to strike punitive damages and attorney’s fees is DENIED. Plaintiffs adequately allege that Defendant engaged in malicious and/or despicable conduct under the cause of action for dependent/adult abuse sufficient to warrant such remedies.

 

The motion to strike allegations regarding covered countermeasures, including those relating to PPE and allegations of willful misconduct that Defendant argues is barred by the PREP Act is DENIED. The Court cannot make factual determinations in response to a Motion to Strike. (See Aubry v. Tri-City Hosp. Dist. (1992) 2 Cal.4th 962, 966-967.) The Court must accept the factual allegations set forth in the FAC as true at this stage in the litigation.