Charlie L. v. Kangavari

CourtCalifornia Court of Appeal
DecidedJanuary 2, 2025
DocketB327714
StatusPublished

This text of Charlie L. v. Kangavari (Charlie L. v. Kangavari) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Charlie L. v. Kangavari, (Cal. Ct. App. 2025).

Opinion

Filed 1/2/25 CERTIFIED FOR PUBLICATION

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION TWO

CHARLIE L., a Minor, etc., B327714

Plaintiff and Appellant, (Los Angeles County Super. Ct. No. v. 21STCV15446)

PEYMAN KANGAVARI, M.D.,

Defendant and Respondent.

APPEAL from a judgment of the Superior Court of Los Angeles County, Olivia Rosales, Judge. Reversed and remanded.

Law Offices of Michels & Lew, Steven B. Stevens, Philip Michels and Jin N. Lew for Plaintiff and Appellant.

Horvitz & Levy, H. Thomas Watson and Peder K. Batalden; Dummit, Buchholz & Trapp, Scott D. Buchholz, Pari H. Granum, and Nicole G. Wells for Defendant and Respondent. Cole Pedroza, Curtis A. Cole and Cassidy Davenport for California Medical Association, California Dental Association, and California Hospital Association as Amicus Curiae on behalf of Defendant and Respondent.

****** To grant physicians and surgeons in general acute care hospital emergency departments a measure of protection from malpractice claims—and thereby to encourage the provision of such emergency medical care—our Legislature enacted what is now Health and Safety Code section 1799.110.1 (Petrou v. South Coast Emergency Group (2004) 119 Cal.App.4th 1090, 1094 (Petrou)); Jutzi v. County of Los Angeles (1987) 196 Cal.App.3d 637, 648 (Jutzi).) The statute accomplishes its purpose in two ways—namely, (1) by modifying the standard of care applicable in malpractice cases to account for the “unique challenges and demands of an emergency room” (Stokes v. Baker (2019) 35 Cal.App.5th 946, 948 (Stokes); § 1799.110, subd. (a)), and (2) by increasing the qualifications an expert must possess before testifying as to whether that altered standard of care was violated in any given case (§ 1799.110, subd. (c)). This case presents the question: Does section 1799.110’s stricter qualifications requirement for expert witnesses apply when the physician being sued was an on-call radiologist who remotely reviewed X-ray and ultrasound images for an emergency department patient on a “stat” basis as requested by the emergency department? We hold that it does, and thus respectfully disagree with Miranda v. National Emergency

1 All further statutory references are to the Health and Safety Code unless otherwise indicated.

2 Services, Inc. (1995) 35 Cal.App.4th 894, 903-904 (Miranda). The trial court here correctly ruled that section 1799.110 applies to the malpractice claims against the on-call radiologist, but incorrectly granted summary judgment after finding the defendant-radiologist’s expert was qualified under that statue but the plaintiff-patient’s expert was not. Because we conclude that neither expert was shown to meet the more stringent test for qualification when the evidence is viewed through the lens applicable on summary judgment, we reverse the judgment for the defendant-physician. FACTS AND PROCEDURAL BACKGROUND I. Facts At 2:07 a.m. on October 11, 2020, three-year-old Charlie L. (plaintiff) was brought by his mother to the emergency department at PIH Health Hospital-Whittier for abdominal pain. Plaintiff had been in and out of hospitals for conditions related to a malrotated bowel he had at birth, for which he had endured several corrective surgeries as well as prior emergency department visits for incidents of vomiting and constipation. At around 3:00 a.m., the emergency department physician treating plaintiff issued “stat” orders for an X-ray and ultrasound of plaintiff’s abdomen. The images were sent for evaluation to Peymam Kangavari, M.D., an “on-call radiologist” working remotely. The X-ray was taken at 3:12 a.m. and Kangavari issued a report based on the images at 3:51 a.m. The ultrasound was taken at 3:24 a.m. and Kangavari issued another report based on those images at 4:35 a.m. Both reports concluded that plaintiff’s bowel was unobstructed. Based on Kangavari’s reports of the imaging results as well as other examinations of plaintiff by

3 emergency department staff, plaintiff was discharged home at 5:54 a.m. with instructions to follow up with his pediatrician and gastroenterologist. Soon after returning home, plaintiff vomited and turned blue. His parents brought him back to the emergency department at 8:18 a.m., nonresponsive with a faint pulse and not breathing. Plaintiff was transferred to Children’s Hospital Orange County later that morning, where he underwent multiple surgeries over the next three days to remove necrotic tissue and the majority of his small bowel due to a lack of blood flow caused by a bowel obstruction. Plaintiff now suffers “short gut syndrome,” has to be fed with a G-tube, wears diapers at all times, and struggles with speech and other mental and emotional capabilities. II. Procedural Background Plaintiff, by and through his mother acting as his guardian ad litem, filed a negligence action against Kangavari on April 23, 2021.2 Plaintiff alleges that Kangavari committed medical malpractice by failing to timely diagnose his bowel obstruction, and alleges that malpractice caused his injuries. Kangavari moved for summary judgment on the grounds that the undisputed facts showed that he adhered to the standard of care (and hence was not negligent), and that any negligence did not cause plaintiff’s injuries. In support of his motion,

2 Plaintiff named other defendants—specifically, PIH Health, Inc., Presbyterian Health Physicians, the hospital, the emergency department physician, and the emergency department physician’s assistant—but plaintiff’s claims against those parties are not at issue on appeal.

4 Kangavari provided the declaration of a diagnostic radiologist, John Lieu, M.D. Plaintiff opposed the motion. In support of his opposition, he provided the declaration of a medical school professor of clinical radiology, Ravi Srinivasa, M.D. During protracted litigation over whether Kangavari could depose plaintiff’s expert in the midst of briefing on the summary judgment motion, Kangavari asserted for the first time that plaintiff’s expert did not meet the qualifications set forth in section 1799.110, which requires experts testifying in certain negligence cases to have specific and “substantial professional experience” in an emergency department.3 Kangavari never deposed the expert, but plaintiff’s expert still filed a supplemental declaration attempting to establish that he had the requisite qualifications. Following a reply brief by Kangavari, objections and responses regarding the admissibility of plaintiff’s expert’s opinion under section 1799.110, and a hearing at which plaintiff objected that Kangavari’s expert also did not meet the qualifications required by the statute, the trial court granted summary judgment for Kangavari.4

3 The trial court initially continued the summary judgment hearing so Kangavari could depose plaintiff’s expert prior to filing his reply brief and, if Kangavari presented any deposition testimony in that reply, the court also granted plaintiff permission to file a sur-reply. Plaintiff then moved to quash the notice of deposition of his expert, and Kangavari argued in opposition, among other things, that the expert lacked the requisite experience to provide a standard of care opinion against an emergency department physician.

4 The parties spill much ink debating the propriety of plaintiff’s supplemental expert declaration, the timeliness of

5 The court (1) ruled that section 1799.110 applies to the malpractice claims against Kangavari; (2) implicitly overruled plaintiff’s objection to Kangavari’s expert’s qualifications under section 1799.110; (3) expressly sustained Kangavari’s objection to plaintiff’s expert’s qualifications under section 1799.110; and (4) ruled that plaintiff’s failure to oppose the motion with expert testimony warranted the grant of summary judgment.

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Charlie L. v. Kangavari, Counsel Stack Legal Research, https://law.counselstack.com/opinion/charlie-l-v-kangavari-calctapp-2025.