DiCampli-Mintz v. County of Santa Clara
55 Cal. 4th 983
| Cal. | 2012Background
- Claimant sued Santa Clara County entities for medical negligence after surgeries at Valley Medical Center.
- Government Claims Act requires claims against local public entities to be presented to designated recipients or deemed rejected.
- Claimant delivered a notice letter (April 3, 2007) to VMC Risk Management, not to the statutorily designated clerk/secretary/auditor or board.
- Letter was not delivered to or received by any statutorily designated recipient; it was received later by County Risk Management but not by proper recipients.
- Court of Appeal held substantial compliance; Supreme Court disapproved, holding actual receipt by designated recipient is required under §915(a)–(e).
- Case involves whether misdirected notices can satisfy presentation requirements and the proper interpretation of §915 to ensure uniform, strict compliance against public entities.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether misdirected claims can satisfy §915 requirements | DiCampli-Mintz argues substantial compliance suffices. | County argues strict statutory delivery/receipt to designated recipients is required. | No; actual receipt by designated recipient required. |
| Whether Jamison/Life framework or earlier cases justify substantial compliance | Plays into substantial compliance based on prior cases. | Prevailing rule supports strict receipt; Jamison is not controlling. | Jamison disapproved; plain language controls; require actual receipt. |
Key Cases Cited
- City of Stockton v. Superior Court, 42 Cal.4th 730 (2007) (reaffirms strict compliance and timeliness for claims against public entities)
- Life v. County of Los Angeles, 227 Cal.App.3d 894 (1991) (misdirected claim must be actually received by proper official; Jamison rejected)
- Del Real v. City of Riverside, 95 Cal.App.4th 761 (2002) (misdirected claim must be actually received by designated recipient; Jamison inappropriate)
- Shirk v. Vista Unified School Dist., 42 Cal.4th 201 (2007) (claims statutes are strict and require proper presentation; not expanded by knowledge)
- Jamison v. State of California, 31 Cal.App.3d 513 (1973) (early rule allowing substantial compliance by misdirected filing; later disapproved)