On October 18, 2016, in Nava v. Saddleback Memorial Medical Center, et al. (Case No. G052218), the Fourth Appellate District, Division Three, published one of the first appellate court Opinions to address the recent California Supreme Court matter of Flores v. Presbyterian Intercommunity Hospital (2016) 63 Cal.4th 75. The Flores Court held that the medical negligence statute of limitations set forth in Code of Civil Procedure § 340.5 applies “when negligence occurs in the use or maintenance of medical equipment or premises while medical care is being provided to the plaintiff.” In Flores, the patient, who had alleged a claim for premises liability, was injured after falling out of her hospital bed when the bedrail latch failed.

In Nava v. Saddleback Memorial Medical Center, in applying the holding in Flores, the Court noted that the patient was injured while transferred in the hospital on a gurney. The patient alleged he suffered a fall during transfer by hospital staff, either from a gurney to an X-ray examination table or from a gurney into an ambulance – he alleged general negligence, and claimed to have been dropped by hospital staff. Saddleback Memorial Medical Center and the defendant ambulance service filed Motions for Summary Judgment, based on application of Section 340.5, contending that the applicable statute of limitations had run. The trial court agreed.

In affirming the Motions for Summary Judgment, the Nava Court held, “[t]he transfer of Nava in the hospital on a gurney was integrally related to Nava’s medical treatment or diagnosis, and, therefore, the injury occurred in the rendering of professional services.” (Emphasis added.) The language, “integrally related,” was specifically used by the Flores Court.

In addition, in affirming the summary judgments, the Nava Court chose to not address pre-Flores cases regarding the meaning of medical negligence for purposes of Section 340.5, instead finding that the Flores matter now governs.

Nava v. Saddleback Memorial Medical Center is one of the first Opinions by a Court of Appeal to cite and rely upon the California Supreme Court’s holding in Flores, and to adopt the Court’s language, “integrally related ” in the context of determining application of the medical negligence statute of limitations, Code of Civil Procedure § 340.5. Pre-Flores cases regarding the meaning of medical negligence for purposes of the applicable statute of limitations (Section 340.5) no longer govern, thereby creating a major shift from prior precedent and a new beginning on the characterization of claims against healthcare providers in future cases.

Haight partners, Angela S. Haskins and Vangi M. Johnson, were trial counsel and appellate counsel, respectively, for Saddleback Memorial Medical Center in this Nava matter.