The Supreme Court of California stated in its July 31, 2025 Opinion: “We granted review in this matter to decide whether the statute of limitations for medical professional negligence claims within the Medical Injury Compensation Reform Act (Code Civ. Proc., § 340.5)1 applies to an action for negligence brought by the injured driver of a vehicle rear-ended by an ambulance transporting a patient. We hold that MICRA’s statute of limitations does not apply under these circumstances. Our holding follows from principles articulated in our previous decisions concerning the scope of MICRA’s statute of limitations, as well as the general rule that the applicable limitations period depends on the nature of the right being sued upon. Where, as here, a plaintiff sues a health care provider for breach of a duty owed to the public generally, as opposed to a violation of professional obligations owed to patients, the two-year statute of limitations for general negligence claims (§ 335.1) applies. This conclusion is supported by MICRA’s text, purpose, and legislative history, as well as relevant public policy considerations.”
“[T]he plaintiff’s status as a patient or nonpatient is not necessarily determinative. Rather, the fundamental question is whether the plaintiff’s claim for negligence involves a violation of professional obligations, as opposed to the breach of a duty owed to the public generally. Applying the foregoing principles, we conclude that the MICRA statute of limitations does not apply here, as plaintiff’s claim stems from the breach of a general duty of care owed to the public.”
“Defendants would have us interpret MICRA more broadly. In their view, the ambulance transport here was “integrally
related” to the provision of health care to the patient passenger (Flores, supra, 63 Cal.4th at p. 88) and, because plaintiff’s injuries resulted from the ambulance transport, his claims should be covered by MICRA. Defendants misunderstand Flores. As previously discussed, in the context of a claim brought by a patient, Flores considered whether the malfunctioning bed guardrail at issue was “integrally related” to the patient’s medical care. (Flores, at p. 89.) Based on a factual concession that her doctor had ordered the guardrail to be set a certain height, we concluded that the patient’s “injuries . . . resulted from [the defendant’s] alleged negligence in the use or maintenance of equipment integrally related to [the patient’s] medical diagnosis and treatment”; therefore, MICRA applied. (Flores, at p. 89.) Here, no similar nexus exists between professional negligence, i.e., the breach of “a duty that the [defendant] owes to a patient by virtue of being a health care provider” (id. at p. 88) and plaintiff’s injuries as alleged in the complaint. Even if we assume the patient in this case was receiving medical services during the ambulance transport, there are no allegations suggesting that professional negligence in rendering those services was the proximate cause of plaintiff’s injuries. In this sense, plaintiff’s claim is distinct from claims by a patient’s relatives for wrongful death or loss of consortium based on medical negligence, or the claims by the foreseeable victims of the dangerous patient in Hedlund.”
Source Gutierrez v. Tostado, S283128.
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