Judge: Ronald F. Frank, Case: 24TRCV01322, Date: 2024-11-01 Tentative Ruling

Case Number: 24TRCV01322    Hearing Date: November 1, 2024    Dept: 8

Tentative Ruling¿¿ 

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HEARING DATE:                 November 1, 2024¿ 

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CASE NUMBER:                      24TRCV01322

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CASE NAME:                           Christopher Meeks, et al. v. Bay Crest Care Center, LLC, et al.

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MOVING PARTY:                Defendants, Bay Crest Care Center, LLC dba Bay Crest Care Center and Rita Simms

                                               

RESPONDING PARTY:       Plaintiffs, Christopher Meeks, individually and as successor-in-interest to James Meeks (deceased); James Louis Meeks, Jr., Brittany Tarsha Emerson, Tavaors Javon Meeks, De’Ante Lasean Emerson

                                               

TRIAL DATE:                       Not Set.

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MOTION:¿                              (1) Defendants Motion to Compel Arbitration

 

Tentative Rulings:                     (1) ARGUE.   The Court tentatively views the gravamen of the Complaint as once sounding in elder abuse rather than medical malpractice which would suggest the motion to compel arbitration of the non-signatory plaintiffs should be denied.  What is the cause of death listed on the death certificate or autopsy?  Did Decedent see a doctor or PA at Bay Crest shortly before his final illness?

 

 

I. BACKGROUND¿¿¿ 

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A.    Factual¿¿¿

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On April 17, 2023, Plaintiffs, Christopher Meeks, individually and as successor-in-interest to James Meeks (deceased); James Louis Meeks, Jr., Brittany Tarsha Emerson, Tavaors Javon Meeks, De’Ante Lasean Emerson (collectively, “Plaintiffs”) filed a complaint against Defendants, Bay Crest Care Center, LLC dba Bay Crest Care Center, Rita Simms, Imelda Punzalan, and DOES 1 through 100. The complaint alleges causes of action for: (1) Elder Abuse and Neglect; (2) Negligence; (3) Violation of Patient’s Bill of Rights; (4) Wrongful Death (Elder Abuse and Neglect); and (5) Wrongful Death (Negligence).

 

Defendants, Bay Crest Care Center, LLC dba Bay Crest Care Center and Rita Sims (“Moving Defendants”) now file a Motion to Compel Arbitration.

 

B.    Procedural¿¿¿ 

 

On September 23, 2024, Moving Defendants filed a Motion to Compel Arbitration and for Stay Action. On October 21, 2024, Plaintiffs filed an opposition brief. On October 25, 2024, Moving Defendants filed a reply brief.

 

 

 

¿II. ANALYSIS¿¿ 

 

A.    Legal Standard

The Federal Arbitration Act (“FAA”) states that “[a] written provision in any . . . contract evidencing a transaction involving commerce to settle by arbitration a controversy thereafter arising out of such contract or transaction . . . shall be valid, irrevocable, and enforceable, save upon such grounds as exist at law or in equity for the revocation of any contract.” (9 U.S.C. § 2.) California law incorporates many of the basic policy objectives contained in the Federal Arbitration Act, including a presumption in favor of arbitrability. (Engalla v. Permanente Medical Group, Inc. (1997) 15 Cal.4th 951, 971-72.)

California law states that “[o]n petition of a party to an arbitration agreement alleging the existence of a written agreement to arbitrate a controversy and that a party to the agreement refuses to arbitrate that controversy, the court shall order the petitioner and the respondent to arbitrate the controversy if it determines that an agreement to arbitrate the controversy exists….” (Code Civ. Proc, § 1281.2.) “The party seeking arbitration bears the burden of proving the existence of an arbitration agreement, and the party opposing arbitration bears the burden of proving any defense, such as unconscionability.” (Pinnacle Museum Tower Assn. v. Pinnacle Market Development (US), LLC (2012) 55 Cal.4th 223, 236.)

Pursuant to Code of Civil Procedure §1281.2, generally, on a petition to compel arbitration, the court must grant the petition unless it finds either (1) no written agreement to arbitrate exists; (2)¿the right to compel arbitration has been waived; (3) grounds exist for revocation of the agreement; or (4) litigation is pending that may render the arbitration unnecessary or create conflicting¿rulings on common issues. 

 

When seeking to compel arbitration, the initial burden lies with the moving party to demonstrate the existence of a valid arbitration agreement by preponderance of evidence.  (Ruiz v. Moss Bros. Auto Group (2014) 232 Cal.App.4th 836, 841-42; Gamboa v. Northeast Community Clinic (2021), 72 Cal.App.5th 158, 164-65.)  It is sufficient for the moving party to produce a copy of the arbitration agreement or set forth the agreement’s provisions.  (Gamboa, 72 Cal.App.5th at 165.)  The burden then shifts to the opposing party to prove by a preponderance of evidence any defense to enforcement of the contract or the arbitration clause.  (Ruiz, 232 Cal.App.4th at 842; Gamboa, 72 Cal.App.5th at 165.)  Subsequently, the moving party must establish with the preponderance of admissible evidence a valid arbitration agreement between the parties.  (Ibid.)  The trial court then weighs all the evidence submitted and uses its discretion to make a final determination.  (Ibid.)  “California law, ‘like [federal law], reflects a strong policy favoring arbitration agreements and requires close judicial scrutiny of waiver claims.’”  (Wagner Const. Co. v. Pacific Mechanical Corp. (2007) 41 Cal.4th 19, 31.) 

 

If the court orders arbitration, then the court shall stay the action until arbitration is completed.  (See Code Civ. Proc., § 1281.4.) 

 

 

 

B.    Discussion

Moving Defendants move to arbitrate this case on the grounds that they argue Decedent and Rebecca Brownslee, a Bay Crest representative, executed an arbitration agreement on January 29, 2018, shortly after he was admitted to Bay Crest. (Declaration of Joeffrey Dykee (“Dykee Decl.”), 2-3, Exhibit B.) Moving Defendants argue that the arbitration agreement stated in bold that Decedent’s agreement to arbitrate was not a condition to be admitted to or receive care at Bay Crest, and further stated, both at the beginning of the agreement and above the signature blocks, in bold and all capital letters, that by agreeing to arbitrate, the party was waiving his right to a trial by judge or jury and should be read carefully. (Dykee Decl., ¶ 3, Exhibit B, p. 1 & 4.) Moreover, Moving Defendants state that Decedent was expressly advised that he could consult an attorney to review the arbitration agreement and had thirty days after signing to cancel the arbitration agreement, but he did not.  The arbitration agreement states, in relevant part:

[i]t is the parties’ intention that this Agreement shall inure to the direct benefit of and bind the Center, its parent, affiliates, subsidiary companies, owners, officer, directors, medical directors, employees, successors, assigns and agents and shall insure to the direct benefit of and bind the Patient, his/her successors, spouses, children, assigns, agents, third party beneficiaries, heirs, trustees and representatives, including the personal representative or executor of his/her estate, and any person whose claim is derived through or on behalf of the Patient.

(Dykee Decl., ¶ 3, Exhibit B, p. 3, § 16.)

[a]ny and all claims or controversies arising out of or in any was relating to this Agreement or to the Patient’s [Meeks] stay at the Center [Bay Crest], including all prior stays at the Center, including disputes regarding interpretation and/or enforceability of this Agreement, whether arising out of state or federal law, whether existing now or arising in the future, whether for statutory, compensatory or punitive damages and whether sounding in breach of contract, negligence, tort or breach of statutory duties (including, without limitation, claims based on personal injury or death), regardless of the basis for any duty or of the legal theories upon which the claim is asserted.

(Dykee Decl., ¶ 3, Exhibit B, p. 1, §2.)

            In opposition, Plaintiffs assert that the motion should be denied because: (1) Plaintiffs’ wrongful death causes of action are rooted in elder abuse and neglect and not in professional negligence, and therefore not subject to Code of Civil Procedure section 1295; (2) there is a high likelihood of conflicting rulings on a common issue of law or fact that the court should deny enforcing the arbitration agreement in its entirety as outlined in Code of Civil Procedure section 1281.2, subdivision (c); and (3) there is neither evidence that the arbitration agreement was explained to Decedent in a form and manner that he understood, nor evidence that Decedent acknowledged that he understood the agreement according to Federal Regulation Code section 483.70 (m).

                          i.          The FAA versus Code of Civil Procedure Section 1295

In Moving Defendants’ moving papers, they argue that both the FAA and California law apply to the arbitration agreement. The court agrees that both provisions apply as the FAA is mentioned in the agreement as well as many references to “state law for the state in which the Center is located.”

First, Plaintiffs oppose the motion on the grounds they argue Code of Civil Procedure section 1295 does not apply to their wrongful death claims that are based on elder abuse and neglect because the code section only applies to professional negligence. Pursuant to Code of Civil Procedure section 1295,

Any contract for medical services which contains a provision for arbitration of any dispute as to professional negligence of a health care provider shall have such provision as the first article of the contract and shall be expressed in the following language: ¿“It is understood that any dispute as to medical malpractice, that is as to whether any medical services rendered under this contract were unnecessary or unauthorized or were improperly, negligently or incompetently rendered, will be determined by submission to arbitration as provided by California law, and not by a lawsuit or resort to court process except as California law provides for judicial review of arbitration proceedings. Both parties to this contract, by entering into it, are giving up their constitutional right to have any such dispute decided in a court of law before a jury, and instead are accepting the use of arbitration.” 

 

(Code Civ. Proc., §¿1295, subd. (a).) 

 

The effect of Section 1295 is that it permits patients who consented to arbitration to bind their heirs in actions for wrongful death when the language of the agreement manifests an intent to bind. (Ruiz v. Podolsky (2010) 50 Cal.4th 838, 849; see also Avila v. Southern California Specialty Care, Inc. (2018) 20 Cal.App.5th 835, 841-842 (“Avila”).) On a claim for wrongful death, however, heirs are only bound when the underlying claim is for professional negligence. (Avila, supra, 20 Cal.App.5th at 841-842.) The Avila Court provided: "[i]f the primary basis for the wrongful death claim sounds in professional negligence as defined by MICRA, then section 1295 applies. If, as plaintiffs claim here, the primary basis is under the Elder Abuse and Dependent Adult Civil Protection Act (Welf. & Inst. Code, § 15600 et seq.) (the Act), then section 1295 does not apply and neither does Ruiz’s exception to the general rule that one who has not consented cannot be compelled to arbitrate." (Id. at 842.) Thus, although Plaintiffs are non-signatories to the arbitration agreement in their individual capacity, they may still be bound by it as heirs to Decedent. As such, the crux of the issue presented is whether the complaint’s wrongful death claim is based on a primary basis of professional negligence or allegations of elder abuse.

            In this case, the complaint alleges causes of action grounded in both elder abuse by neglect as well as negligence. Although the complaint does not explicitly state a claim or even make reference to the term “professional negligence,” Avila’s holding does not turn on whether the pleading states a claim for professional negligence, but rather whether the “primary basis” for the wrongful death claim sounds in professional negligence or elder abuse. The Court of Appeals in Avila instructs that the difference between the two claims rests on whether the pleading alleges a failure to provide medical services, which reads as elder abuse; or the substandard performance of medical services that were provided. (Id. at 843.)

The first and third causes of action based on elder abuse and fraud assert that Defendants neglected Decedent when they: “failed to exercise the degree of care that reasonable persons in a like position would exercise by denying or withholding goods or services necessary to meet the basic needs of Decedent MEEKS, specifically including the failure to assist in personal hygiene, or in the provision of food, clothing or shelter, the failure to provide medical care for physical and mental health needs, the failure to protect from health and safety hazards, and the failure to prevent malnutrition or dehydration.” (Complaint, ¶ 104.) This court notes that although these allegations (especially which claim “deny,” “withhold,” and “failed to…”) intuitively read as elder abuse, the allegations are often pared with other allegations of failure to provide care to an adequate standard of care. Allegations such as those read more as the substandard provision of medical services, rather than the failure to provide such services. Again, this court emphasizes that Elder neglect does not refer to substandard performance of medical services but rather 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. (Avila, at p. 843, 230 Cal.Rptr.3d 42; see Fenimore v. Regents of University of California (2016) 245 Cal.App.4th 1339, 1348-1349, 200 Cal.Rptr.3d 345.)

            The court will allow oral argument on this issue as to whether the complaint reads more as a failure to provide medical services versus substandard performance of medical services. However, the court finds that under Avila and Ruiz, Plaintiffs’ claims read more so as substandard performance of medical services.

                        ii.          Applicability of Code of Civil Procedure Section 1281.2, Subdivision (c)

The remaining non-wrongful death causes of action, including Plaintiffs’ survivor claims for dependent adult abuse, negligence and violation of patient’s bill of rights remain at issue. Moving Defendants have suggested this court follow the recent decision in Holland v. Silverscreen Healthcare (2024) 101 Cal.App.5th 1125 (although recently granted review by the Supreme Court) while Plaintiffs suggests reliance on that case may only be instructive, and that instead, this court should rely on Hearden v. Windsor Redding Care Center, LLC, et al. (2024) 103 Cal.App.5th 1010.

In Hearden, four (4) residents of a defendant care center passed away due to COVID-19 infections.  Family members of those residents subsequently filed suit against the defendant care center, individually and as successors-in-interest to the decedents.  The defendant care center subsequently moved to compel arbitration based on four (4) agreements signed by the successor family members.  (Hearden, supra, 103 Cal.App.5th at pp. 1013-1014.) The lower court denied the defendant care center’s motion to compel arbitration in Hearden, “finding that as to three of the agreements, there was no evidence the family signatory had authority to sign on behalf of the decedent; as to all four of the agreements, there was no evidence the family signatory agreed to arbitrate their individual claim; and as to one successor claim in which the family signatory had power of attorney, the trial court exercised its discretion to deny the motion to compel arbitration to avoid the possibility of conflicting results.”  (Id. at 1014.)

 

The Hearden Court of Appeal determined that the trial court appropriately exercised its discretion in denying the motion to compel arbitration.  In reaching this conclusion, the Court of Appeal emphasized that Code of Civil Procedure section 1281.2 (c) “gives a trial court discretion to deny a motion to compel arbitration as to all or part of an arbitrable controversy when ‘[a] party to the arbitration agreement is also a party to a pending court action or special proceeding with a third party, arising out of the same transaction or series of related transactions and there is a possibility of conflicting rulings on a common issue of law or fact.’”  (Id. at 1017, quoting Code Civ. Proc., § 1281.2 (c).)

 

In Moving Defendants’ reply brief, they argue Hearden is distinguishable because the vast majority of the claims asserted by the plaintiffs (elder abuse, violation of patient’s bill of rights, unfair competition, wrongful death, and fraud) were either found to be predicated on elder neglect versus the lone cause of action for professional negligence or expressly excluded from arbitration by the agreement’s terms, such that it was well within the Court’s discretion to find under section 1281.2, subdivision (c), that there was a possibility of conflicting rulings militating the denial of the motion to compel arbitration. (Hearden, supra, 103 Cal.App.5th at pp. 1017-20.) Moving Defendants assert that here, Plaintiff’s violation of patient’s bill of rights claim is not excluded from the agreement and is predicated on medical negligence, and Plaintiffs’ allegation of a separate wrongful death claim based on medical negligence, and all other survivor claims (i.e., elder abuse and negligence causes of action) are all expressly contemplated in the agreement as being arbitrable. However, Moving Defendants concede that only one of the five causes of action alleged (the wrongful death – elder abuse & neglect claim) is arguably not subject to binding arbitration.

 

The court seeks oral argument based on the issue of maintaining certain causes of action in the court and sending the rest to arbitration.

 

                      iii.          Defenses to Arbitration

Plaintiffs argue that the Moving Defendants failed to demonstrate that the arbitration agreement was explained to Decedent and that he understood what he was signing. However, in reply, Moving Defendants note the express delegation clause in Section 9 of the arbitration agreement, as they cited to in the moving papers, which militates that the arbitrator, not the court, shall determine the agreement’s validity, interpretation, construction, performance, and enforcement. The court agrees that such delegation clause warrants such.

                       iv.          Stay of Superior Court Action

Depending on the parties’ arguments to the questions requested above, this court notes that the decision to stay this action pending arbitration will depend on the decisions on the issues above.