Hi-Desert Medical Center v. Douglas
239 Cal. App. 4th 717
| Cal. Ct. App. | 2015Background
- SB 1103 (2004-2005) imposed a reimbursement cap on noncontract Medi-Cal hospitals, including the petitioners.
- Dignity Health, Hi-Desert, Modoc, and Mee challenged SB 1103 in separate actions and administrative proceedings over several years.
- Mission Hospital Regional Medical Center v. Douglas (
- The Court of Appeal (Third District) issued rulings in Mission I and Mission II affecting the petitioners’ monetary relief claims.
- Administrative law judges dismissed the petitioners’ administrative appeals after Mission II, and the petitioners sought writs of mandate in superior and appellate courts.
- The trial court and appellate decision held that the petitioners’ monetary-relief claims were barred by res judicata (or forfeiture for Modoc) due to prior Mission litigation and lack of opposition to a key motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the administrative actions are barred by res judicata | Dignity Health/Hi-Desert/Mee: relief barred by prior final Mission judgments. | Department: prior Mission decisions preclude relitigation of the same claim. | Yes; barred by res judicata. |
| Whether Modoc forfeited its rights by not opposing the ALJ's dismissal | Modoc challenges jurisdiction to dismiss; faults in procedure. | Modoc abandoned its administrative action by not opposing the dismissal. | Yes; forfeiture; dismissal proper. |
| Whether Dignity Health's methodological challenge is barred by res judicata | Dignity Health seeks retroactive relief under SB 1103 based on 2003 costs. | Relief barred merging into Mission I/II; improper collateral attack remains barred. | Yes; barred by res judicata. |
| Whether equity/public-interest considerations override res judicata | Equitable/public-interest weigh against applying res judicata to deny monetary relief. | Overriding public interest favors finality and judicial resource conservation. | No; res judicata applies; equity does not compel override. |
Key Cases Cited
- Boeken v. Philip Morris USA, Inc., 48 Cal.4th 788 (Cal. 2009) (primary rights theory; same injury supports res judicata)
- Mycogen Corp. v. Monsanto Co., 28 Cal.4th 888 (Cal. 2002) (definition of cause of action and primary right)
- Mata v. City of Los Angeles, 20 Cal.App.4th 141 (Cal. App. 1993) (mandamus procedural limits; res judicata considerations)
- Mission Hospital Regional Medical Center v. Douglas (Mission I), 168 Cal.App.4th 460 (Cal. App. 2008) (SB 1103 challenge; prospective relief only; notice/operational defects)
- Daugherty v. Board of Trustees, 111 Cal.App.2d 519 (Cal. App. 1952) (agency not acting beyond jurisdiction; historical context)
- Warner v. North Orange County Community College Dist., 99 Cal.App.3d 617 (Cal. App. 1979) (damages in mandamus context; exhaustion considerations)
- Wenzler v. Municipal Court, 235 Cal.App.3d 128 (Cal. App. 1965) (damages and mandamus; monetary relief contexts)