Daniel C. v. White Memorial Medical CenterAnnotate this Case
Appellant is a severely disabled child whose congenital abnormalities went undetected during his mother’s pregnancy until after viability. Appellant sued various medical providers for wrongful life, settling with one in 2018. The California Department of Health Care Services (DHCS) asserted a lien on Appellant's settlement to recover what DHCS paid for Appellant's care. The trial court awarded DHCS the full amount of the lien and Appellant appealed.
The Second Appellate District reversed. Although the court rejected Appellant's claim that the DHCS lien is preempted by federal law and that there is no substantial evidence that Appellant's settlement included payments for past medical expenses, the Second Appellate District found that the trial court erred by failing to distinguish between past medical expenses and other damages.