C.T. v. County of San Diego CA4/1

CourtCalifornia Court of Appeal
DecidedFebruary 3, 2026
DocketD085349
StatusUnpublished

This text of C.T. v. County of San Diego CA4/1 (C.T. v. County of San Diego CA4/1) 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
C.T. v. County of San Diego CA4/1, (Cal. Ct. App. 2026).

Opinion

Filed 2/3/26 C.T. v. County of San Diego CA4/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

C.T., D085349

Plaintiff and Appellant,

v. (Super. Ct. No. 37-2022- 00016689-CU-PO-CTL) COUNTY OF SAN DIEGO,

Defendant and Respondent.

APPEAL from a judgment of the Superior Court of San Diego County, Carolyn Caietti, Judge. Reversed. Herman Law, Justin Felton and Sarah Serrano for Plaintiff and Appellant. Office of County Counsel, Talia V. Edelman and Katie A. Richardson, Deputy County Counsel, for Defendant and Respondent. INTRODUCTION C.T. sued the County of San Diego (County) for negligence based on sexual abuse she alleged she suffered 50 years ago while in foster care. She asserted the County was liable because her social worker negligently placed her with her abuser, failed to adequately monitor her abuser while she was in his care, failed to create and implement reasonable polices to protect foster children in the foster care system, and failed to conduct a reasonable investigation and remove her from the foster home within a reasonable time after she reported the sexual abuse. She also alleged the County violated a mandatory statutory duty because it failed to cross-report her allegations to law enforcement. The County obtained summary judgment. Because the alleged abuse took place so long ago, this case raises uniquely narrow issues. This is because much of the evidence about what happened no longer exists. The County destroyed relevant records in the ordinary course of business pursuant to Welfare and Institutions Code section 826 and Government Code section 68152. And many of the issues we address are specific to the laws and legal landscape that were in effect in the mid-1970s. For reasons we shall explain in detail below, we reverse the judgment.

FACTUAL AND PROCEDURAL BACKGROUND1 C.T. was born in 1967. She was removed from her parents’ care when she was approximately five years old. Throughout her childhood, she moved back and forth between her mother’s care and various foster homes in San Diego County.

1 Under the governing standard of review, we examine the evidence de novo and our account of the facts is presented in the light most favorable to C.T. (the nonmoving party) and, where the evidence is in conflict, assumes her version of all disputed facts is the correct one. (See Miller v. Department of Corrections (2005) 36 Cal.4th 446, 470; Birschtein v. New United Motor Manufacturing, Inc. (2001) 92 Cal.App.4th 994, 999.)

2 In 1975, when C.T. was about eight years old, she was placed in a foster home with M.P. and his wife for about four to six months. M.P. began sexually abusing her shortly after she was placed in his care, and she reported the abuse to her social worker during her second home visit. As explained by C.T. during her deposition, she told the social worker that M.P. was “touching me and hurting me,” and she wanted to go back to her mother. The social worker “immediately” spoke with C.T.’s foster mother. C.T. was in another room during this conversation, but she could overhear some of what they said through the wall. C.T. heard her social worker tell her foster mother about the allegations. She heard her foster mother say she did not believe the abuse occurred and tell the social worker that C.T.’s mother had told her that C.T. “makes up stories.” The social worker then left without asking C.T. any additional questions. C.T. subsequently told her aunt, mother, and grandmother about the abuse, but she did not know whether they spoke with the social worker. C.T. also did not know whether the social worker spoke with M.P. M.P. continued abusing C.T. until the social worker visited again several weeks later and removed her from the home. By this time, C.T. believed M.P.’s wife had witnessed the abuse and no longer believed she was making it up. The social worker did not tell C.T. why she was removed. During discovery, the County could not identify C.T.’s social worker. C.T.’s juvenile court and Health and Human Services Agency (HHSA) records were destroyed pursuant to Welfare and Institutions Code section 826 and Government Code section 68152. The County conducted a search of its other records and was unable to identify a foster parent named M.P. with a placement history during the relevant timeframe. And although C.T. remembered her social worker as “a middle-aged African American female”

3 named “ ‘Pam’ or ‘Pamela,’ ” the County needed a “last name, date of birth, and/or social security number” to identify a former employee during the relevant timeframe. C.T. believed the social worker was employed by the County because she was living in San Diego when she was placed in foster care. She also believed her social worker was responsible for placing her in M.P.’s home. In May 2022, C.T. sued the County for negligence based on the sexual assaults that continued after she reported the sexual abuse to her social worker. Relevant here, the operative complaint (FAC) alleged the County was (1) directly liable for negligence under Government Code section 815.6 “for its failure to discharge mandatory duties set forth in . . . Penal Code section[ ] . . . 11166” and various other statutes, and (2) vicariously liable for negligence committed by C.T.’s social worker pursuant to sections 815.2 and 820. In April 2024, the County moved for summary judgment based on several independent grounds. First, the County asserted it was not directly liable for failure to perform a mandatory duty because the statutory duties identified in the FAC all arose out of statutes that did not exist in the 1970s. Second, the County asserted it was not vicariously liable because the decisions of government-employed social workers and independent contractors “relating to the investigation of child abuse and removal of a minor from a home” are discretionary decisions subject to immunity under Government Code section 820.2. Third, the County asserted that C.T. failed to identify a County employee and her abuser with sufficient specificity to establish the County owed a duty of care to her. Finally, the County asserted the statute of limitations barred C.T.’s suit.

4 The trial court granted the County’s motion in August 2024 based on its first two contentions. The court ruled that direct liability for failure to perform a mandatory duty was precluded because C.T. did not allege the County violated a statute that was in effect in 1975 (or 1976 or 1977). The court further ruled that vicarious liability for negligence on the part of the social worker was precluded because the County was immune from liability pursuant to Government Code section 820.2 “for alleged negligence in investigating reports of child abuse.” The court did not reach the County’s other contentions. DISCUSSION C.T. contends the trial court erred when it granted summary judgment for the County. Based on our independent review, we conclude the court correctly ruled that C.T.’s direct liability claim against the County failed as a matter of law because the FAC did not identify a statute that was in effect during the relevant period. We further reject C.T.’s contention—made for the first time on appeal—that a predecessor statute created a mandatory duty that obligated the County to cross-report suspected child sexual abuse reported to the County’s social workers. This contention is both forfeited and incorrect on the merits.

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C.T. v. County of San Diego CA4/1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ct-v-county-of-san-diego-ca41-calctapp-2026.