Judge: Lee W. Tsao, Case: 23NWCV02616, Date: 2024-01-17 Tentative Ruling

Case Number: 23NWCV02616    Hearing Date: January 17, 2024    Dept: C

Andrade, et al. v. La Mirada, et al.

CASE NO.:  23NWCV02616

HEARING 1/17/24 @ 10:30 AM

#9

 

Defendant Morado’s Demurrer to the First Cause of Action is SUSTAINED with leave to amend within 30 days of this order.

Moving Party to give NOTICE.

 

Defendant Andrew Morado, MD (Morado) demurs to the First Cause of Action for Elder Abuse in Plaintiff Juan Andrade’s (Plaintiff) Complaint on the grounds that it fails to plead facts to support a cause of action.

Background

Plaintiff Juan Andrade, by and through his successor in interest, Maria Andrade, filed a Complaint alleging Elder Abuse and Negligence against Defendants Morado and La Mirada Healthcare (La Mirada) (collectively Defendants) and Violation of Patient’s Bill of Rights against Defendant La Mirada. Plaintiffs Maria Andrade and Benny Andrade alleged a Wrongful Death cause of action against Defendants.

Erwin Andrade and Luz Howard were named as nominal defendants because they are heirs of Plaintiff, however, they chose to not participate in the lawsuit.

Legal Standard

The party against whom a complaint has been filed may object to the pleading, by demurrer, on several grounds, including the ground that the pleading does not state facts sufficient to constitute a cause of action. (CCP § 430.10(e).) A party may demur to an entire complaint, or to any causes of action stated therein. (CCP § 430.50(a).) “‘[A] demurrer based on an affirmative defense will be sustained only where the face of the complaint discloses that the action is necessarily barred by the defense.’” (McKenney v. Purepac Pharmaceutical Co. (2008) 167 Cal.App.4th 72, 78-79.)

Meet and Confer

The Court finds that the parties adequately met and conferred.

Discussion

Plaintiff alleges that he was in the care and custody of Morado during his stays at La Mirada, a skilled nursing facility.  Specifically, Plaintiff alleges in the Complaint that:

8. Defendant ANDREW MORADO, M.D. and DOES 51-75 (hereinafter “DR. MORADO”) and each of them, were physicians licensed by the State of California. DR. MORADO lists his business address 5451 La Palma Avenue, Ste. 19, La Palma, CA 90623. DR. MORADO entered into a physician-patient relationship with PLAINTIFF to care for PLAINTIFF’s medical needs while he was hospitalized and while PLAINTIFF was a resident at FACILITY. Additionally, MORADO was PLAINTIFF’s attending physician throughout all times relevant to this case. DR. MORADO wrote multiple orders for treatment and medications that hospital and nursing home staff were required to follow. DR. MORADO was part of a care team responsible for PLAINTIFF while he was a patient at FACILITY. This care team, including DR. MORADO, was responsible for ongoing assessments of PLAINTIFF while he was a patient at FACILITY and was responsible, along with FACILITY staff, for deciding when PLAINTIFF should be transferred to the hospital. Additionally, DR. MORADO made ongoing treatment decisions for PLAINTIFF while he was a patient at the hospital and at FACILITY. This care team, including DR. MORADO, took responsibility for and directed care for PLAINTIFF’s basic needs, which an able-bodied and fully competent adult would ordinarily be capable of managing without assistance. 

28. PLAINTIFF was originally hospitalized on June 17, 2022. At the time, he was diagnosed with, among other things, c-diff colitis, a urinary tract infection from his Foley catheter, and malnutrition because his appetite had decreased. C-diff colitis is an intestinal issue that results in severe diarrhea and potential damage to the colon if left untreated. The resulting diarrhea can cause severe dehydration and malnutrition if immediate medical care is not provided. After receiving treatment at the hospital, PLAINTIFF was transferred to FACILITY and admitted on June 30, 2022. PLAINTIFF was a resident of FACILITY from June 30, 2022 through July 11, 2022 when he was hospitalized again. PLAINTIFF returned to FACILITY on July 15, 2022 where he remained until August 2, 2022.

29. On admission on June 30, PLAINTIFF was under in the care and custody of DR. MORADO, who was PLAINTIFF’s attending physician throughout his time at FACILITY. PLAINTIFF was also in the care and custody of FACILITY staff. At the time, FACILITY and DR. MORADO knew PLAINTIFF’s history of c-diff, malnutrition, and the fact he still required a Foley catheter and had a recent history of urinary tract infection. FACILITY and DR. MORADO knew that decreased appetite, abdominal pain, and diarrhea, among other things, were signs and symptoms that PLAINTIFF’s urinary tract infection and c-diff infection were recurring. Indeed, FACILITY implemented a care plan that required staff to notify DR. MORADO of any of these symptoms, which DR. MORADO was also aware of. 

30. During PLAINTIFF’s June 30 to July 11 admission to FACILITY, PLAINTIFF was noted to have low blood pressure and was easily fatigued. This was especially true during physical and occupational therapy sessions. Due to these troubling findings, FACILITY staff contacted DR. MORADO who ordered transfer to the hospital on July 11. This is an indication that both FACILITY and DR. MORADO were aware of the importance of transferring PLAINTIFF to the hospital emergently if his condition deteriorated. During his July 11 to July 15 hospital admission, PLAINTIFF was diagnosed by DR. MORADO with COVID-19, failure to thrive, c-diff, and a urinary tract infection among other diagnoses. At the time of discharge from the hospital, DR. MORADO failed to implement any meaningful treatment for PLAINTIFF’s c-diff. DR. MORADO knew at the time that his failure to adequately treat PLAINTIFF’s c-diff posed a substantial likelihood that PLAINTIFF’s c-diff would continue to worsen and cause permanent damage to PLAINTIFF’s colon if not treated appropriately. 

Defendant argues that Plaintiff fails to adequately plead facts sufficient to constitute a claim for elder abuse with particularity. Elder abuse requires:

(1) defendant had responsibility for meeting the basic needs of the elder or dependent adult, such as nutrition, hydration, hygiene or medical care;

(2) defendant knew of conditions that made the elder or dependent adult unable to provide for his or her own basic needs;

(3) defendant denied or withheld goods or services necessary to meet the elder or dependent adult's basic needs, either:

a. with knowledge that injury was substantially certain to befall the elder or dependent adult (if the plaintiff alleges oppression, fraud or malice); or

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

As to the first element, Plaintiff argues that elder abuse does not require pleading the defendant was a care custodian. However, the Supreme Court ruled that the plaintiff must allege that they are in the “care or custody” of the defendant and “care or custody” requires robust caretaking or custodial relationship, “involving ongoing responsibility for one or more basic needs, with the elder patient.” Thus, Plaintiff must plead that he was in a caretaking or custodial relationship with Morado. Here, Plaintiff has not adequately pleaded that he was in a caretaking or custodial relationship with Morado. Elder Abuse causes of action must be plead with particularity. (Carter v. Prime Healthcare Paradise Valley LLC (2011) 198 Cal.App.4th 396.) Plaintiff alleges vague facts that Morado had an ongoing responsibility for assessments and directing care of Plaintiff’s basic needs. (Compl. ¶ 8.) “As used in [Welf. & Inst. Code § 15610.57], 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.’” (Covenant Care, Inc. v. Superior Court (2004) 32 Cal.4th 771, 783.) Plaintiff has failed to plead specifically what basic needs Morado was responsible for and how the ongoing treatment and assessments were such that they would constitute a basic need as opposed to normal medical care. Plaintiff’s allegations in Paragraphs 28-30 of the Complaint relate to Morado’s alleged failure to provide medical services and not any failure to attend to the basic needs of Plaintiff. The allegations detail Morado’s alleged substandard care of Plaintiff’s C-diff colitis. Thus, Plaintiff has failed to adequately plead that he was in the care or custody of Morado. Therefore, Defendant Morado’s Demurrer to the First Cause of Action for Elder Abuse is sustained.

Leave to amend is granted because this is the first demurrer to Plaintiff’s Complaint.

 

Accordingly, Defendant Morado’s Demurrer to the First Cause of Action is SUSTAINED with leave to amend within 30 days of this order.