Justia Health Law Opinion Summaries

The case involves Taylor Capito, who filed a class action lawsuit against San Jose Healthcare System, LP, also known as Regional Medical Center San Jose, challenging the assessment of Evaluation and Management Services (EMS) fees for two emergency room visits. Capito argued that Regional had a duty to notify emergency room patients about EMS fees beyond listing them in the chargemaster, such as through posted signage or during the patient registration process. She claimed that Regional's failure to do so constituted an unlawful, unfair, or fraudulent business practice under the Unfair Competition Law (UCL) and violated the Consumers Legal Remedies Act (CLRA).The trial court sustained Regional's demurrer without leave to amend, and the Court of Appeal affirmed. The appellate court reasoned that hospitals do not have a duty to disclose EMS fees beyond what is required by the relevant statutory and regulatory framework, following the reasoning in similar cases like Gray v. Dignity Health and Saini v. Sutter Health. The Court of Appeal also affirmed the trial court's order striking the class allegations in Capito's first amended complaint.The Supreme Court of California reviewed the case and affirmed the Court of Appeal's judgment. The court held that hospitals do not have a duty under the UCL or CLRA, beyond their obligations under the relevant statutory and regulatory scheme, to disclose EMS fees prior to treating emergency room patients. The court emphasized that requiring such disclosure would alter the balance of competing interests, including price transparency and the provision of emergency care without regard to cost, as reflected in the multifaceted scheme developed by state and federal authorities. The court also dismissed Capito's appeal from the trial court's order striking her class allegations as moot. View "Capito v. San Jose Healthcare System, LP" on Justia Law

This case involves a dispute over the interpretation of the "learned intermediary doctrine" in a product liability case involving a medical device. The plaintiff, Michelle Himes, sued the defendant, Somatics, LLC, alleging that the company failed to provide adequate warning about the risks associated with electroconvulsive therapy (ECT), a treatment she underwent for severe depression. Himes claimed that she was only warned about the possibility of short-term memory loss, and not about the potential for permanent brain damage, severe permanent retrograde and anterograde amnesia, and acute and/or chronic organic brain syndrome, which she alleges she suffered as a result of the treatment.The district court granted summary judgment in favor of Somatics, finding that Himes failed to present evidence showing that a more detailed warning would have changed her physician's decision to administer ECT. The Ninth Circuit Court of Appeals agreed with the district court's finding but noted a genuine dispute of material fact as to whether the physician would have communicated a stronger warning to Himes.The Supreme Court of California was asked to clarify the causation standard under the learned intermediary doctrine. The court held that a plaintiff is not required to show that a stronger warning would have altered the physician’s decision to prescribe the product to establish causation. Instead, a plaintiff may establish causation by showing that the physician would have communicated the stronger warning to the patient and an objectively prudent person in the patient’s position would have thereafter declined the treatment. The court emphasized that the causation analysis must take into consideration whether the physician would still recommend the prescription drug or medical device for the patient, even in the face of a more adequate warning. View "Himes v. Somatics, LLC" on Justia Law

In 2019, Emily Wheeler, a property owner, was charged with various violations of the Los Angeles Municipal Code related to unlicensed cannabis activity on her property. Wheeler, who was 85 years old and had no criminal record, claimed she had no knowledge of the illegal activity. The trial court dismissed the charges against her, citing her age, clean record, and lack of knowledge about the illegal activity on her property. The People appealed the dismissal, arguing that the trial court erred in considering Wheeler's lack of knowledge because the charges were strict liability offenses.The appellate division of the superior court reversed the dismissal, agreeing with the People that the trial court should not have considered Wheeler's lack of knowledge. The appellate division reasoned that since the charges were strict liability offenses, Wheeler's lack of knowledge was not mitigating. Wheeler then petitioned the Court of Appeal for a writ of mandate to affirm the trial court's dismissal, but the Court of Appeal affirmed the appellate division's decision.The Supreme Court of California reversed the Court of Appeal's judgment. The Supreme Court held that a trial court has discretion to consider a defendant's lack of knowledge when deciding whether to dismiss charges in furtherance of justice under Penal Code section 1385, even for strict liability offenses. The Supreme Court reasoned that the nature of the charged offense and a defendant's minimal culpability can be relevant considerations for a section 1385 dismissal. The Supreme Court remanded the case to the Court of Appeal with instructions to issue a writ of mandate directing the appellate division to affirm the trial court's dismissal. View "Wheeler v. Appellate Division of Superior Court" on Justia Law

The Supreme Court of California considered whether a health care agent, who had signed two contracts with a skilled nursing facility on behalf of a principal, had the authority to sign an optional, separate arbitration agreement. The first contract ensured the principal’s admission to the facility, while the second made arbitration the exclusive method for resolving disputes with the facility. The court concluded that the execution of the arbitration contract was not a "health care decision" within the authority of the health care agent. Therefore, the facility’s owners and operators could not rely on the agent’s execution of the arbitration agreement to compel arbitration of claims arising from the principal’s alleged maltreatment. The court affirmed the judgment of the Court of Appeal and remanded the case for further proceedings. View "Harrod v. Country Oaks Partners, LLC" on Justia Law

In the case, a defendant, Mario Rodriguez, was charged with several felonies, each carrying a maximum sentence exceeding two years. In 2018, Rodriguez was found mentally incompetent to stand trial and committed to a state hospital. After a certificate indicating his restoration to competency was filed within the two-year time limit, Rodriguez was returned to court. However, due to COVID-19 restrictions, his hearing to confirm his competency did not take place within the two-year period. Rodriguez sought to dismiss the charges against him, claiming the time for commitment had run out.The Supreme Court of California held that under the relevant statutes, the time between the filing of a certificate of restoration of mental competency and the court's ruling on that certificate counts towards the two-year maximum commitment period mandated by section 1370(c)(1) of the California Penal Code. Therefore, the filing of a certificate of restoration does not end the period of mental incompetency commitment.The court sent the case back to the Court of Appeal to decide whether the two-year limit was exceeded in this case, and if so, what remedy Rodriguez might be entitled to. The court did not decide whether Rodriguez was entitled to the remedy of dismissal he sought, or whether and how the issue of tolling may affect Rodriguez's entitlement to any relief. View "Rodriguez v. Super. Ct." on Justia Law

The Supreme Court held that persons facing involuntary commitment under the Sexually Violent Predator Act (SVP Act), Cal. Welf. & Inst. Code 6600 et seq., have a due process right to a timely trial but that whether pretrial delay violates that right depends in the first instance on the reasons for the delay. See Barker v. Wingo (1972), 407 U.S. 514, 531.In 2005, Petitioner was determined to be an SVP and committed to the state hospital for two years. The next year, the applicable statute was amended to provide for indefinite commitment instead of renewable two-year terms. Before Petitioner's term ended, the State filed a recommitment petition seeking indefinite commitment under the new version of the statute. Petitioner later filed a motion to dismiss the petition to extend commitment, arguing that the "excessive delay" in his case violated his due process right to a timely trial. The trial court denied the motion to dismiss, after which Petitioner filed an original petition for a writ of mandate. The court of appeal denied the writ petition. The Supreme Court affirmed, holding that Petitioner failed to establish a violation of his due process rights. View "Camacho v. Superior Court" on Justia Law

The Supreme Court reversed the decision of the court of appeal affirming the conclusion of the State Department of Health Care Services that the costs of outreach and education activities aimed at Medicaid-eligible patients were categorically nonreimbursable, holding that the chief administrative law judge's ruling was an abuse of discretion.Health care providers entitled to government reimbursement, including federally qualified health centers (FQHCs), for reasonable costs related to the care of Medicaid beneficiaries are required to offer outreach and education activities to members of underserved communities. The FQHC operator in this case sought reimbursement for the outreach and education costs, but the Department determined that the costs were nonreimbursable. The court of appeal affirmed. The Supreme Court reversed, holding that the Department's determination rested on a misunderstanding of relevant legal principles governing the reimbursement of medical provider costs. View "Family Health Centers of San Diego v. State Dep't of Health Care Services" on Justia Law

The Supreme Court reversed the judgment of the court of appeal affirming the judgment of the court of appeal granting summary judgment for the defense in this lawsuit brought by the California Medical Association (CMA), holding that the evidence was sufficient to create triable issues of fact precluding summary judgment.CMA, a nonprofit professional association representing California physicians, sued Aetna Health of California Inc. alleging that Aetna violated the unfair competition law (UCL), Cal. Bus. & Prof. Code 17200 et seq., by engaging in unlawful business practices. At issue was whether Aetna satisifed the UCL's standing requirements by diverting its resources to combat allegedly unfair competition. The Supreme Court held (1) the UCL’s standing requirements are satisfied when an organization, in furtherance of a bona fide, preexisting mission, incurs costs to respond to perceived unfair competition that threatens that mission, so long as those expenditures are independent of costs incurred in UCL litigation or preparations for such litigation; and (2) the trial court erred in granting summary judgment for Aetna on the ground that CMA lacked standing. View "Cal. Medical Assn. v. Aetna Health of Cal., Inc." on Justia Law

The Supreme Court held that because Plaintiff's state-law claims were based on allegations that his father's health maintenance organization (HMO) plan and healthcare services administrator that managed his father's benefits (collectively, Defendants) breached state-law duties that incorporated and duplicated standards established under Medicare Part C, Part C's preemption provision preempted them.Plaintiff brought this action alleging a state statutory claim under the Elder Abuse Act and common law claims of negligence and wrongful death for the alleged maltreatment of his father, a Medicare Advantage (MA) enrollee who died after being discharged from a skilled nursing facility. Plaintiff alleged that the MA HMO and healthcare services administrator breached a duty to ensure his father received skilled nursing benefits to which he was entitled under his MA plan. Defendants demurred, arguing that the claims were preempted by Part C's preemption provision. The trial court sustained the demurrers, and the court of appeal affirmed. The Supreme Court affirmed, holding that because Plaintiff's state-law claims were based on allegations that Defendants breached state-law duties that incorporate and duplicate standards established under Part C, the claims were expressly preempted. View "Quishenberry v. UnitedHealthcare, Inc." on Justia Law

The Supreme Court held that a claim for reimbursement of emergency medical services may be maintained against a health care service plan when the plan is operated by a public entity and that the Government Claims Act, Cal. Gov. Code 810 et seq., did not immunize the County of Santa Clara from such a claim in this case.Two hospitals submitted reimbursement claims for the emergency medical services they provided to three individuals enrolled in a County-operated health care service plan. The hospitals sued for the remaining amounts based on the reimbursement provision of the Knox-Keene Act, and the trial court concluded that the hospitals could state a quantum merit claim against the County. The court of appeal reversed, determining that the County was immune from suit under the Government Claims Act. The Supreme Court reversed, holding that the County was not immune from suit under the circumstances of this case and that the hospitals' claims may proceed. View "County of Santa Clara v. Superior Court" on Justia Law