Court Holds Plaintiff was Injured by Defendant’s Breach of Duties Owed to the Public Under California Law

In a California premises liability case involving whether the trial court properly applied the Medical Injury Compensation Act’s (MICRA) one-year statute of limitations for professional negligence, the appellate court held that it had been an error to apply the one-year statute of limitations for professional negligence. The court assessed whether the statute of limitations applied to bar her case, since the plaintiff argued that her injury was not caused by rendering professional services but in fact was caused by ordinary negligence.

The facts indicate that the plaintiff had been at a medical clinic, with the goal of reviewing test results with a nurse-practitioner. After her consult, the plaintiff left the treatment room in order to exit the building.  She tripped on a scale that, she alleged, partly blocked the path from her room to the hall. As she tripped, she fell and suffered serious injuries.

The plaintiff’s complaint was filed nearly two years after the incident, and the health center alleged her injuries were caused by “a negligent act or omission in rendering professional services.” As a result, they contended she was subject to the one-year statute of limitations for professional negligence, and her complaint was time-barred.

On appeal, the court made clear the issue was which statute of limitations should apply to her claim:  the one-year limitation for injuries caused by medical professional negligence, or the two-year statute of limitations for personal injuries.  The trial court had determined that the plaintiff was hurt in the course of obtaining medical treatment by equipment used to diagnose and treat medical conditions. For those reasons, the one-year statute of limitations for professional negligence applied.

Regarding the duty owed by a health care provider to the general public, as compared to the duties owed to patients, the court stated that it can be “difficult to ascertain.”  According to law, there is a distinction between the professional obligations that hospitals owe patients and the obligations that they owe the public, since their premises are open to all users.

In this case, the court stated that the plaintiff had been injured after her medical care was completed, as a result of a breach of duties that were generally owed to all visitors to the medical clinic.  She did trip on medical equipment, but she had not alleged that a failure to maintain the medical scale affected the quality of her treatment or care. Instead, the court stated she had implicated the facility’s duty to all users, whether patients or employees, to maintain a safe premises.

The court made clear that they intended to avoid making ordinary premises liability claims subject to the special, one-year statute of limitations.  Since the plaintiff had been injured by a breached obligation that was owed to the public, the trial court had erred when they applied the one-year MICRA statute of limitations.

The court reversed the judgment and remanded for further proceedings.

The attorneys at Sharifi Firm help people throughout Southern California in personal injury cases seeking compensation for accident-related costs.  Contact our office to schedule a free consultation with a dedicated premises liability attorney.  We can be reached by calling (866) 422-7222.

More Blog Posts:

California Court Holds No Error in Lower Court’s Judgment Dismissing Plaintiff’s Complaint After Motor Vehicle Collision Because Statute of Limitations Had Run, Southern California Injury Lawyer Blog, September 7, 2017

California Appellate Court Holds Paramedic Failed to Exercise Care When Driving Rather Than When Rendering Professional Services, So Two-Year Statute of Limitations Applies and Plaintiff’s Claim not Time-Barred, Southern California Injury Lawyer Blog, August 15, 2016

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