Pouzbaris v. Prime Healthcare Services
Annotate this CasePlaintiff Asama Pouzbaris appealed the grant of summary judgment entered in favor of defendant Prime Healthcare Services-Anaheim LLP d/b/a West Anaheim Medical Center. Plaintiff alleged that while she was a patient at defendant’s hospital, she slipped and fell on a recently mopped floor that lacked any warning signs. Defendant obtained summary judgment on the ground plaintiff’s action was barred by the one-year statute of limitations period imposed by the Medical Injury Compensation Reform Act of 1975 (MICRA). The issue this case raised on appeal was whether a hospital’s purported conduct in mopping a floor and failing to provide warning signs constitutes “professional negligence” within the meaning of section 340.5 rather than ordinary negligence subject to the two-year limitations period under section 335.1. The California Supreme Court had granted review of a case involving the similar issue concerning a hospital’s alleged negligence in allowing a patient’s bed rail to collapse. (Flores v. Presbyterian Intercommunity Hospital (2013) 213 Cal.App.4th 1386, review granted May 22, 2013, S209836.) The Court of Appeal concluded this case fell within the two-year statute.
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