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1 Year Statute of Limitations for Medical Providers Does Not Apply to Premises Liability Claims

October 10, 2017

Johnson v. Open Door Community Health Centers, California Court of Appeal, First District, Division 4 (Reardon, J.); September 11, 2017; 2017 WL3976813

Why this Case is Important

In Johnson v. Open Door Community Health Centers, decided on September 11, 2017, the California Court of Appeal held that the Medical Injury Compensation Reform Act’s (“MICRA”) (Code Civ. Proc., § 340.5) one-year statute of limitations for professional negligence applies only when the injury’s legal cause relates to the “rendering of professional services,” and not to ordinary negligence claims. This decision limits the reach of MICRA’s one-year statute of limitations to injuries caused by a breach of a duty owed exclusively to the patient during the rendering of professional services, rather than the public at large.

Facts

The Court in Johnson, 2017 WL3976813, reversed the trial court’s entry of summary judgement for Defendant, Open Door Community Health Center (“Open Door”), because the trial court misapplied MICRA’s one-year statute of limitations to a premises liability action. The Plaintiff, Claudia Johnson (“Johnson”), visited Open Door to review the results of certain tests taken in the past. Upon being admitted, Johnson was weighed on a scale located outside of a treatment room and then given a consultation regarding the test results. After the consultation ended, Johnson tripped on the scale, which was allegedly moved during her consultation and left partially obstructing the walk way. Johnson suffered serious injuries as a result of the fall and sued Open Door for the personal injuries. Open Door filed a motion for summary judgment, arguing that MICRA’s one-year statute of limitations applied because Johnson’s injury occurred in the course of obtaining medical treatment and was caused by equipment used to treat her. The trial court granted Open Door’s motion for summary judgment and Johnson appealed the ruling.

The Ruling

The Court of Appeal reversed the trial court’s ruling, relying on the California Supreme Court’s guiding principals for ascertaining whether an injury’s legal cause is “the rendering of professional services” or simply ordinary negligence, as set forth in Flores v. Presbyterian Intercommunity Hosp. (2016) 63 Cal.4th 75. In Flores, the California Supreme Court held that courts must “draw a distinction between the professional obligations of hospitals in the rendering of medical care to their patients and the obligations hospitals have, simply by virtue of operating facilities open to the public, to maintain their premises in a manner that preserves the well-being and safety of all users.” Id. at 87. Applying the Flores guidelines, the Court held that the general, two-year statute of limitations for personal injury was the appropriate standard, not the special one-year statute under MICRA. The Court noted that Johnson was initially weighed without incident and the injury occurred only after her care was complete. Johnson, 2017 WL3976813, at 3. Further, because the tripping hazard created by the improperly placed scale implicated a duty owed to all of Open Door’s users of its facility, rather than a duty owed solely to Johnson as a patient, the Court found the one-year MICRA statute of limitations was inappropriate.

Conclusion

This decision limits the scope of MICRA’s one-year statute of limitations to actions resulting from breaches of duties owed exclusively to patients in the rendering of professional services, rather then mere breaches of duties owed to the public at large.

 

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