Johnson v. Alameda County Medical Center
140 Cal. Rptr. 3d 281
Cal. Ct. App.2012Background
- Alameda County Medical Center operates John George Psychiatric Pavilion, a county mental hospital.
- In June 2005, Lisa Johnson and Cedrick Frowner were involuntarily held patients at JGPP.
- Johnson was allegedly sexually assaulted by Frowner; door-lock misalignment allegedly allowed entry.
- Department of Health Services found the door latch faulty; hospital plan of correction described misalignment.
- Regulations require hospitals be in good repair; locks on patient rooms in county psychiatric hospitals are not required.
- Trial court granted summary judgment in favor of the Medical Center on immunity grounds; appeal followed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether immunity under Gov. Code § 854.8 applies | Johnson argues exceptions to immunity may apply due to facility failures. | Medical Center shows no injury caused by an employee or failure to provide required facilities. | Immunity applies; no triable issue on employee-specific liability. |
| Whether § 855 exception for inadequate equipment or facilities applies | Breach of minimum standards due to improper locks constitutes § 855 liability. | No statute or regulation required locks on county hospital patient rooms; § 855 requires specific minimum standards. | No § 855 liability; no specific minimum standards proven. |
| Whether trial court properly denied further discovery | Need discoverable facts to identify responsible employees and establish exceptions to immunity. | Too late and lacked diligence; discovery period long past; no good cause shown. | Discretionary denial of discovery affirmed; no abuse of discretion. |
Key Cases Cited
- Lockhart v. County of Los Angeles, 155 Cal.App.4th 289 (Cal. App. 2007) (requires specific minimum standards for § 855 liability)
- Baber v. Napa State Hospital, 209 Cal.App.3d 213 (Cal. App. 1989) (minimum standards may be proven by collateral evidence; but plaintiff bears burden)
- Park v. First American Title Co., 201 Cal.App.4th 1418 (Cal. App. 2011) (summary judgment continuance standards; abuse of discretion standards for discovery rulings)