Judge: Ronald F. Frank, Case: 24TRCV00279, Date: 2024-06-25 Tentative Ruling

Case Number: 24TRCV00279    Hearing Date: June 25, 2024    Dept: 8

Tentative Ruling¿ 

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HEARING DATE:                 June 25, 2024¿ 

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CASE NUMBER:                  24TRCV00279

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CASE NAME:                        Isabelle Clayton, et al. v. Torrance Memorial Medical Center, et al.  

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MOVING PARTY:                Defendants, Providence Health System – Southern California dba Providence Little Company of Mary Medical Center and Providence Health System – Southern California dba Providence Little Company of Mary Transitional Care Center

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RESPONDING PARTY:       Plaintiffs, Isabelle Clayton, by and through her successor-in-interest, Norma Calhoun, Norma Calhoun, individually, Karmela Calhoun, individually, Cedric Clayton, individually, and Sheryl Pearson, individually.

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TRIAL DATE:                        None set.  

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MOTION:¿                              Demurrer¿to the 1st cause of action, alleged Elder Abuse 

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Tentative Rulings:                  SUSTAINED with twenty (20) days leave to amend.

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I. BACKGROUND¿¿ 

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A. Factual¿¿ 

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On January 26, 2024, Plaintiffs, Isabelle Clayton, by and through her successor-in-interest, Norma Calhoun, Norma Calhoun, individually, Karmela Calhoun, individually, Cedric Clayton, individually, and Sheryl Pearson, individually (collectively “Plaintiffs”) filed a complaint against Defendants, Providence Health System – Southern California dba Providence Little Company of Mary Medical Center and Providence Health System – Southern California dba Providence Little Company of Mary Transitional Care Center (collectively, “Defendants”) and DOES 1 through 200.

 

The complaint alleges causes of action for: (1) Elder Abuse; (2) Negligence; (3) Violation of Residents Rights; and (4) Wrongful Death. The complaint is based on Plaintiffs’ allegations that on April 27, 2022, Plaintiff, Isabelle Clayton was admitted to LCOM for right lower extremity weakness. On May 10, 2022, Plaintiffs contend that Plaintiff, Isabelle Clayton was admitted to LCOM Transitional where it was noted she had a coccyx pressure injury. Then, on June 17, 2022, Plaintiffs note that Plaintiff, Isabelle Clayton was admitted to TMMC for left arm weakness and slurred speech, where admission records indicate she had a stage two (2) sacral pressure injury. Further, on August 9, 2022, Plaintiffs contend Isabelle Clayton was admitted to TMMC from LCOM Transitional due to urinary obstruction, progressive fever and a urine culture positive for E.coli. On August 31, 2022, Plaintiffs note that Isabelle Clayton was noted as having a stage 4 pressure injury to her coccyx/sacrum was measured as unstageable. Plaintiffs allege that while under the care and treatment of Defendants, Isabelle Clayton developed pressure injuries to her sacrum/coccyx which caused her to endure extreme pain and suffering and suffer an untimely demise.

 

Defendants file a Demurrer to Plaintiffs’ complaint.

 

B. Procedural¿¿ 

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On May 7, 2024, Defendants filed this demurrer to Plaintiffs’ complaint. On June 11, 2024, Plaintiffs filed an opposition brief. On June 17, 2024, Defendants filed a reply brief.  

 

II. ANALYSIS¿ 

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A.    Legal Standard

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A demurrer can be used only to challenge defects that appear on the face of the pleading under attack or from matters outside the pleading that are judicially noticeable. (Blank v. Kirwan (1985) 39 Cal.3d 311, 318.) “To survive a demurrer, the complaint need only allege facts sufficient to state a cause of action; each evidentiary fact that might eventually form part of the plaintiff’s proof need not be alleged.” (C.A. v. William S. Hart Union High School Dist. (2012) 53 Cal.4th 861, 872.) For the purpose of testing the sufficiency of the cause of action, the demurrer admits the truth of all material facts properly pleaded. (Aubry v. Tri-City Hospital Dist. (1992) 2 Cal.4th 962, 966-967.) A demurrer “does not admit contentions, deductions or conclusions of fact or law.” (Daar v. Yellow Cab Co. (1967) 67 Cal.2d 695, 713.)¿¿¿ 

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A pleading is uncertain if it is ambiguous or unintelligible. (Code Civ. Proc., § 430.10, subd. (f).) A demurrer for uncertainty may lie if the failure to label the parties and claims renders the complaint so confusing defendant cannot tell what he or she is supposed to respond to.¿ (Williams v. Beechnut Nutrition Corp. (1986) 185 Cal.App.3d 135, 139, fn. 2.) However, “[a] demurrer for uncertainty is strictly construed, even where a complaint is in some respects uncertain, because ambiguities can be clarified under modern discovery procedures.” (Khoury v. Maly's of California, Inc. (1993) 14 Cal.App.4th 612, 616.)¿¿ 

 

B.     Meet and Confer

 

Before filing a demurrer, the demurring party is required to meet and confer “in person, by telephone, or by video conference with the party who filed the pleading that is subject to the demurrer for the purposes of determining whether an agreement can be reached through a filing of an amended pleading that would resolve the objections to be raised in the demurrer.” (Code Civ. Proc., § 430.41, subd. (a).) 

 

Pursuant to the declaration of David R. Tredway, Esq., counsel for Defendants, on April 24, 2024, he emailed a meet and confer letter to Plaintiffs; counsel in a good faith effort to meet and confer regarding their believed deficiencies in the complaint. (Declaration of David R. Tredway, Esq. (“Tredway Decl.”), ¶ 2.)  Tredway further notes that he also had a discussion with Plaintiffs’ counsel regarding this on May 3, 2023. Despite their efforts, the parties were unable to reach an agreement resolving the disputes at issue.

 

Plaintiffs’ opposition brief does not dispute Defendants’ meet and confer efforts. As such, this Court finds that the parties met and conferred in good faith prior to Defendants filing of the demurrer.

 

C.    Discussion

 

Defendants demur to Plaintiffs’ complaint on the grounds they argue the first cause of action for elder abuse fails to state sufficient facts to constitute a cause of action against Defendants and is uncertain, ambiguous, and unintelligible.

 

Elder Abuse

            First, Defendants argue that elder abuse is not an available cause of action where it is based on the provider’s alleged professional negligence. The Elder Abuse and Dependent Adult Civil Protection Act (Welf. & Inst. Code, § 15600 et seq.) provides for steep penalties against those who abuse an elder or a dependent adult. Dependent adult abuse includes physical abuse, neglect, isolation, deprivation by a care custodian of necessary goods or services, and financial abuse. (Welf. & Inst. Code, § 15610.07, subd. (a).) Neglect includes failure to assist in personal hygiene, failure to provide medical care for physical and mental health needs, and failure to protect from health and safety hazards. (Welf. & Inst. Code, § 15610.57, subd. (b).)

As far as allegations for professional negligence are alleged, case law is clear that “‘neglect’ within the meaning of Welfare and Institutions Code section 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. 

 

In order to distinguish Dependent Adult Abuse from Professional Negligence, there must be a showing of recklessness, fraud, malice, or oppression. (See Covenant Care, Inc., supra, 32 Cal.4th at 783.) “Oppression, fraud, and malice involve intentional, willful, or conscious wrongdoing of a despicable or injurious nature.” (Carter v. Prime Healthcare Paradise Valley LLC (2011) 198 Cal.App.4th 396, 405 (internal quotation marks omitted).) Recklessness requires deliberate disregard of a high degree of probability an injury will occur. (Id.) The enhanced remedies for Elder Abuse are only available for “acts of egregious abuse against elder and dependent adults.” (Id.) There must be an allegation of authorization or ratification on the part of a managing agent in order to recover damages for dependent adult abuse against corporate defendants. (See Civ. Code, § 3294; Cal. Welf. & Inst. Code, § 15657(c).)  

 

To plead elder abuse, the plaintiff must allege “facts establishing that the defendant: (1) had responsibility for meeting the basic needs of the elder or dependent adult, such as nutrition, hydration, hygiene or medical care [citations]; (2) knew of conditions that made the elder or dependent adult unable to provide for his or her own basic needs [citations]; 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 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) [citations].” (Carter v. Prime Healthcare Paradise Valley LLC (2011) 198 Cal.App.4th 396, 406-07.) “The plaintiff must also allege . . . that the neglect caused the elder or dependent adult to suffer physical harm, pain or mental suffering.” (Id. at 407.) “[T]he facts constituting the neglect and establishing the causal link between the neglect and the injury ‘must be pleaded with particularity,’ in accordance with the pleading rules governing statutory claims.” (Id. (quoting Covenant Care, Inc. v. Superior Court (2004) 32 Cal.4th 771, 790).)  

            Here, the Court finds that the complaint does allege: (1) that Demurring Defendants had a responsibility for meeting the basic needs of decedent by failing to take the necessary steps to properly care for her pressure injuries (Complaint, ¶¶ 33, 38); (2) that Demurring Defendants knew that taking the necessary precautions to prevent her from incurring avoidable pressure injuries, was critical to her health, well-being, and prognosis (Complaint, ¶¶ 34, 39); (3) that by failing to address the decedent’s patient care issues, Demurring Defendants knew it was highly probable that she would suffer pressure injuries and knowingly disregarded that risk (Complaint, ¶¶ 34, 39.) Plaintiff also alleges that as a result of the Demurring Defendant’s wrongdoings, decedent suffered physical harm, pain and mental suffering. (Complaint, ¶ 30.) Thus, the Complaint does contain facts which allege the required elements of this cause of action.

            The Court also finds that the Complaint alleges facts to establish employer liability. Before any damages may be imposed against an employer for an employee’s conduct, an officer, director, or managing agent of the employer must have had advance knowledge of the employee’s unfitness and a conscious disregard of the rights of others or authorized or ratified the wrongful conduct. (See Welf. & Inst. Code, § 15657, subd. (c).); Civ. Code, § 3294, subd. (b).) The Complaint contains the allegation that “Defendants had advance knowledge of the unfitness of their employees and employed them with a conscious disregard of the rights or safety of others, “authorized or ratified the wrongful conduct” and Defendant’s conduct was “on the part of an officer, director, or managing agent of the corporation” (Complaint, ¶ 31.)  This allegation is vague and conclusory, and is insufficient to satisfy the heightened pleading requirements described in the published precedents, including Carter v. Prime Healthcare, supra, 198 Cal.App.4th at p. 407 which lists seven examples of particularized pleading which had not been met in that case.  The Second District recently reversed and remanded a medical malpractice/Elder Abuse jury verdict for a new trial on the issues of respondeat superior and ratification in Samantha B. v. Aurora Vista Del Mar, LLC (2022) 77 Cal.App.5th 85.  While we are a long way away from trial of this matter, the specificity of pleading entity responsibility for allegedly intentional or reckless acts by staff members is properly raised by Demurrer.  Greater detail is required, using Carter, Covenant Care, and Samantha B as guideposts for the level of detail required. 

Further, Plaintiff’s Complaint alleges that Demurring Defendants acted with recklessness, oppression, and malice in a conclusory way. (Complaint, ¶¶ 34, 39.) Such allegations do not meet the pleading requirements required to allege statutory elder abuse versus professional negligence. For example, how did Demurring Defendants act to rise to the level of reckless, oppression, and malice? How did Demurring Defendants authorize or ratify the conduct? Without more, Plaintiff may not maintain this cause of action as against Demurring Defendants.

            As such, the Demurrer is SUSTAINED with twenty (20) days leave to amend.  

IV. CONCLUSION¿¿ 

 

For the foregoing reasons, Demurring Defendant’s demurrer is SUSTAINED with twenty (20) days leave to amend.

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Defendants are ordered to give notice.¿¿¿¿ 

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