Cravotta v. State of Cal. CA3

CourtCalifornia Court of Appeal
DecidedJuly 23, 2025
DocketC100643
StatusUnpublished

This text of Cravotta v. State of Cal. CA3 (Cravotta v. State of Cal. CA3) 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
Cravotta v. State of Cal. CA3, (Cal. Ct. App. 2025).

Opinion

Filed 7/23/25 Cravotta v. State of Cal. CA3 NOT TO BE PUBLISHED California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA THIRD APPELLATE DISTRICT (Sacramento) ----

ANTHONY CRAVOTTA II, C100643

Plaintiff and Appellant, (Super. Ct. No. 34-2022- 00329028-CU-PO-GDS) v.

STATE OF CALIFORNIA et al.,

Defendants and Respondents.

Timely claim presentation under the Government Claims Act is a condition precedent to a plaintiff’s maintaining an action against a public entity. (Shirk v. Vista Unified School Dist. (2007) 42 Cal.4th 201, 209 (Shirk); Gov. Code, §§ 810 et seq.; 945.4 [statutory section citations that follow are to the Government Code].) “Complaints that do not allege facts demonstrating either that a claim was timely presented or that compliance with the claims statute is excused are subject to a general demurrer for not stating facts sufficient to constitute a cause of action.” (Shirk, at p. 209.)

1 Plaintiff Anthony Cravotta II, through his guardian ad litem and counsel, presented a claim to defendants State of California and the California Department of State Hospitals (collectively, the Department) to recover for severe injuries he incurred while he was an inmate in a county jail waiting to be transferred to a Department state hospital for treatment and to gain competency to stand trial. Approximately 85 days after plaintiff presented his claim, the Department informed plaintiff that it had determined the claim was filed untimely. But the Department also determined that the claim included an application for leave to present a late claim, and it told plaintiff it would review the application. Before receiving any response from the Department and without filing a petition with the superior court for relief from the claim filing requirement, plaintiff filed this action. The trial court sustained the Department’s demurrer to the second amended complaint without leave to amend and dismissed the action. It ruled that plaintiff violated the Government Claims Act by not timely filing a petition with the superior court for relief from the claim filing requirement, a statutory requirement for challenging a public entity’s denial of an application to file a late claim. (§ 946.6, subd. (a).) Plaintiff appeals from the judgment of dismissal. He contends (1) he presented a timely claim and not an application to present a late claim, and the trial court erred by determining on demurrer the discovery rule did not delay accrual of his action; (2) the Department waived its timeliness defense by not providing him with the notice required by section 911.3; and (3) his claim was timely under the doctrine of equitable tolling. We reverse. We conclude that plaintiff’s claim was deemed denied as a matter of law, and he could file this action without first petitioning the superior court for relief. We will also direct the trial court to grant plaintiff leave to amend the complaint with specific factual allegations showing the time and manner of his discovering his cause of action and his inability to have made discovery earlier despite reasonable diligence.

2 FACTS AND HISTORY OF THE PROCEEDINGS “Because this case comes before us on appeal from a judgment sustaining a demurrer, we assume the truth of the facts alleged in the complaint and the reasonable inferences that may be drawn from those facts.” (Miklosy v. Regents of University of California (2008) 44 Cal.4th 876, 883.) More than 20 years ago, plaintiff was diagnosed with mental illness, including depression and bi-polar disorders. He has been on and off medications and in and out of mental health facilities for the majority of his life, including being committed under Welfare and Institutions Code section 5150 on several occasions. His illness limits his ability to care for himself, think, communicate, process information, and control and express his thoughts and emotions. On November 11, 2020, plaintiff was arrested and charged with possession of child pornography in violation of Penal Code section 311.11, subdivision (a). He was booked into the Sacramento County Main Jail. Jail staff designated him to be housed in the jail’s psychiatric services unit. A clinical assessment concluded that plaintiff had a history of schizoaffective disorder. He presented with disorganized thought and speech characterized by nonsensical, disconnected statements. He was “ ‘clearly psychotic’ ” and “ ‘gravely disabled.’ ” On December 10, 2020, plaintiff was reclassified and discharged from the psychiatric services unit. He was placed in the jail’s general population with a recommendation for outpatient psychiatric housing. He continued to exhibit psychotic behavior while in the general population. The criminal court on February 22, 2021, determined that plaintiff was incompetent to stand trial. The court suspended the proceedings and referred plaintiff to the Department’s Conditional Release Program (CONREP). On April 5, 2021, the court

3 reviewed the CONREP report, and it ordered plaintiff be placed at a Department state hospital pending restoration of his competency. Despite the criminal court’s order, the Department did not transfer plaintiff and admit him to a state hospital. Plaintiff remained in the jail’s general population where he continued to exhibit psychotic behavior. In August 2021, the jail reclassified plaintiff to a lower security level of “ ‘Medium’ ” on its inmate security classification scale of low, medium, or high. On August 24, 2021, the criminal court scheduled a hearing to discuss plaintiff’s transfer to the Department, as plaintiff “was ordered to the state hospital on April 5, 2021, but he remains at the main jail.” The court’s minutes from the hearing, held September 15, 2021, state plaintiff was “ ‘#26 on the waiting list for transportation to [jail-based competency treatment] (sometime in November).’ ” On September 24, 2021, the jail reassigned plaintiff to share a cell with Lemar Burleson in the jail’s general population. Burleson suffered from mental illness. At one point, the jail housed him in its total separation housing isolated from other inmates. Jail staff reports noted that Burleson had “ ‘extreme psych issues’ ” and had often threatened to assault any inmate he was housed with. Like plaintiff, Burleson was waiting to be transferred and admitted to a state hospital. The complaint alleges that on the same day, September 24, plaintiff’s “jail mental health notes identified that he ‘said he got a new cellmate but “It’s not working out too well.” Writer asked [him] to elaborate, but [he] said “I would rather talk to my attorney lawyer about it.” [He] denied any physical or sexual contact occurred with his current cell-mate, but said “if he gets physical I’ll have to defend myself.” [H]e inquired about when he will go to [the state hospital] and talked about his next court date and said he’s “praying for the judges.” ’ ” On September 26, 2021, Burleson attacked plaintiff inside their cell. Plaintiff sustained catastrophic injuries, including permanent brain injuries. He was transported to

4 a hospital and placed into a medically induced coma. There is no prognosis that he will recover from his brain injuries. Burleson was later charged with attempted murder of plaintiff. The criminal court granted plaintiff compassionate release from custody on October 14, 2021. He remains hospitalized. He requires continuous medical care, which he is expected to require for the remainder of his life.

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