California Supreme Court Watch

#22-211 County of Santa Clara v. Superior Court, S274927. (H048486; 77 Cal.App.5th 1018; Santa Clara County Superior Court; 19CV349757.) Petition for review after the Court of Appeal issued a writ of mandate in a civil action. This case presents the following issue: Is Santa Clara County immune under the Government Claims Act (Gov. Code, § 810 et seq.) from an action seeking reimbursement for emergency medical care provided to persons covered by the county’s health care service plan?

Petition for review granted; issues limited: 7/27/2022

Case fully briefed: 2/01/2023

Cause argued and submitted: 5/10/2023

Opinion filed: Judgment reversed: 7/10/2023

See the Court of Appeal Opinion.

See the Petition for Review.

See the Oral Argument.

See the California Court of Appeal Opinion.  (County of Santa Clara v. Superior Court (2023) 14 Cal.5th 1034.)

“In this case, Doctors Medical Center of Modesto, Inc., and Doctors Hospital of Manteca, Inc., (collectively, the Hospitals) provided emergency medical services to three individuals enrolled in a health care service plan operated by the County of Santa Clara (the County). The Hospitals submitted reimbursement claims to the County, but the County paid only a portion of the claimed amounts. The Hospitals sued the County for the remaining amounts based on the Knox-Keene Act’s reimbursement provision [Health & Saf. Code, § 1340 et seq.]. The trial court found that the Hospitals could state a quantum meruit claim against the County. On petition for writ of mandate, the Court of Appeal disagreed, holding that the County is immune from suit under the Government Claims Act and that no exception to immunity applies.

We conclude that the Government Claims Act does not bar the Hospitals’ action against the County. The immunity provisions of the Government Claims Act are directed toward tort claims; they do not foreclose liability based on contract or the right to obtain relief other than money or damages. (Gov. Code, § 814.) The Hospitals have not alleged a conventional common law tort claim seeking money damages. Instead, they have alleged an implied-in-law contract claim based on the reimbursement provision of the Knox-Keene Act, and seek only to compel the County to comply with its statutory duty. Accordingly, the County is not immune from suit under the circumstances and the Hospitals’ claim may proceed.”

Chief Justice Guerrero authored the opinion of the Court, in which Justices Corrigan, Liu, Kruger, Groban, Jenkins, and Evans concurred.