Nava v. Saddleback Memorial Medical Center, et al. is the latest in a line of cases regarding the definition of professional negligence in matters involving health care providers and the applicable statute of limitations. The Fourth Appellate District’s recent decision in Nava is one of the first opinions by a Court of Appeal to cite and rely on the California Supreme Court’s holding in Flores v. Presbyterian Intercommunity Hospital, and to adopt the Court’s language, “integrally related” in determining application of the medical negligence statute of limitations.
Partner Angela Haskins co-authored the article “A Claim is for Medical Negligence – Not General Negligence – When ‘Integrally Related’ to a Patient’s Medical Treatment or Diagnosis” in Verdict Magazine, discussing the significance of this decision.
“Pre-Flores cases regarding the meaning of professional negligence for purposes of the applicable statute of limitations (Section 340.5) no longer govern, thereby creating a major shift from prior precedent and a new beginning on the characterization of claims against healthcare providers in future cases.”