Leonetti v. Patel CA5

California Court of Appeal·Decided July 29, 2026·No. F089403·Unpublished

Opinion

Filed 7/28/26 Leonetti v. Patel CA5

NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIFTH APPELLATE DISTRICT

MARK LEONETTI et al., F089403 Plaintiffs and Appellants, (Super. Ct. No. CV-23-005729) v.

VATSAL B. PATEL, OPINION Defendant and Respondent.

APPEAL from a judgment of the Superior Court of Stanislaus County. John R. Mayne, Judge. Law Offices of Brown & Gessell, Steven L. Brown and Douglas A. Gessell for Plaintiffs and Appellants. Salinas Law Group, Richard S. Salinas and Nicholas J. Penner for Defendant and Respondent. -ooOoo- Plaintiffs and appellants Mark Leonetti (Leonetti) and Piret Leonetti (collectively, plaintiffs) appeal from a judgment entered in favor of defendant Vatsal Patel, M.D. (Dr. Patel) and against plaintiffs after Dr. Patel successfully moved for summary judgment on the ground the lawsuit against him was barred by the one-year statute of limitations for medical malpractice claims. The appeal centers around plaintiffs’ attempt to substitute Dr. Patel as a named defendant in the lawsuit in place of a Doe defendant after the one-year limitations period expired. The trial court concluded, in essence, that plaintiffs could not use the Doe substitution procedure to add Dr. Patel in as a named defendant because Dr. Patel’s name and identity were sufficiently known to plaintiffs at the time they filed the complaint, and the Doe substitution procedure is not available to a plaintiff if the would-be defendant’s name “is known or could very easily be known by them.” The court also rejected plaintiffs’ contention that Dr. Patel was already adequately named as a defendant in the complaint. The court granted Dr. Patel’s motion for summary judgment. We affirm the judgment. FACTUAL AND PROCEDURAL BACKGROUND On October 3, 2023, plaintiffs filed a complaint in Stanislaus Superior Court (complaint) alleging the defendants named in their lawsuit were negligent and committed malpractice in rendering healthcare services to Leonetti. Plaintiffs alleged that, as a result, they suffered wage loss, hospital and medical expenses, general damage, loss of earning capacity, emotional distress, and loss of consortium. Plaintiffs used a Judicial Council form1 to draft their complaint. The caption on the first page of the complaint reads:

“PLAINTIFF: MARK LEONETTI and PIRET LEONETTI [¶]

1 Judicial Council form PLD-PI-001, COMPLAINT—Personal Injury, Property Damage, Wrongful Death.

2. “DEFENDANT: GENESIS CARE USA OF CALIFORNIA; (See Attachment 1)” The complaint continued as follows: “Plaintiff (name or names): Mark Leonetti and Piret Leonetti allege[] causes of action against defendant (name or names): Genesis Care USA of California; (See Attachment 1).” Attachment 1 of the complaint identified the following additional defendants: “KAISER FOUNDATION HOSPITALS, a non-profit corporation; KAISER FOUNDATION HEALTHPLAN, INC.; and THE PERMANENTE MEDICAL GROUP, INC.” Plaintiffs also sued fictitiously named defendants Does 1 to 25. No other persons or entities were expressly identified as named defendants in the complaint. Under the heading “description of reasons for liability,” plaintiffs alleged the following:

“In October, 2022 and thereafter, defendants provided medical care related to the treatment of [Leonetti] for nasal cancer. Plaintiff, [Leonetti] and his family, were assured that the treatment, which included radiation treatment, would not include his throat area. Contrary to his informed consent, and below the requisite standard of care, [Leonetti’s] throat was irradiated, causing significant damages and injuries to him and his wife. [Leonetti] discovered this treatment that was contrary to his wishes and below the standard of care on or about October 6, 2022. [Leonetti] had been referred to Dr. Patel, at Genesis Care [USA of California], for oncological radiation treatment by his treating healthcare providers at Kaiser. Kaiser was negligent in their referral and their failure to ensure both the quality of care that was required by the standard of care and the appropriateness of that care to [Leonetti]. This care and treatment provided to [Leonetti] was not indicated and not consented to.” Despite mentioning “Dr. Patel” in the body of their complaint, plaintiffs did not include Dr. Patel among the expressly named defendants identified in their complaint. However, on January 19, 2024, plaintiffs filed an amendment to their complaint to substitute “Vatsal B. Patel, M.D.” (i.e., Dr. Patel) in as a named defendant in place of Doe 1, alleging that plaintiffs were previously ignorant of his true name (the Doe

3. amendment). Based on the allegations of the complaint, the Doe amendment was filed one year and three-and-a-half months after the date plaintiffs discovered the alleged negligence and medical malpractice. On February 22, 2024, Dr. Patel filed his answer to plaintiffs’ complaint. Dr. Patel generally denied the allegations of the complaint and alleged 18 affirmative defenses. Among those affirmative defenses, Dr. Patel alleged “the action is barred by the appropriate statute of limitations as set forth in Code of Civil Procedure sections 335.1 and 340.5, and [Dr. Patel] requests a separate trial in regard to this defense pursuant to Code of Civil Procedure section 597.5.” On October 16, 2024, Dr. Patel filed a motion for summary judgment or, in the alternative, summary adjudication. The motion for summary judgment was premised on Dr. Patel’s contention that plaintiffs’ claims are time-barred under Code of Civil Procedure section 340.5,2 which provides a one-year statute of limitations for personal injury claims due to professional negligence. On January 10, 2025, the trial court granted Dr. Patel’s request for summary judgment and entered judgment in his favor. On February 13, 2025, Dr. Patel served plaintiffs with notice of entry of judgment. On February 20, 2025, plaintiffs timely filed a notice of appeal. DISCUSSION I. Standard of Review “Appellate courts determine de novo whether an issue of material fact exists and whether the moving party was entitled to summary judgment as a matter of law. [Citation.] Upon review, the appellate court applies the same three-step analysis as the trial court. [Citation.] This requires the court to (1) identify the issues framed by the

2 All further statutory references are to the Code of Civil Procedure unless otherwise stated.

4. pleadings, (2) determine whether the moving party has established facts justifying judgment in its favor, and (3) determine whether the nonmoving party has demonstrated a triable issue of material fact. [Citation.] In conducting its review, the appellate court must, ‘view the evidence in a light favorable to plaintiff as the losing party.’ [Citation.] Under the three-step analysis, the moving party bears the initial burden of showing there is no genuine dispute of material fact and that it is entitled to judgment as a matter of law. [Citation.] Typically, to meet this burden, a defendant moving for summary judgment can either negate an element of the cause of action or demonstrate a complete defense to plaintiff’s claim. [Citation.] Only if the defendant meets its initial burden does the burden shift to the plaintiff to show a triable issue exists.” (Jones v. Awad (2019) 39 Cal.App.5th 1200, 1206–1207.) II. Analysis A. The Statute of Limitations and the Doe Amendment The parties do not dispute that the one-year limitation period contained in section 340.5 applies to plaintiffs’ claims. Section 340.5 provides, in relevant part:

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