Meikle v. County of Orange CA4/3

CourtCalifornia Court of Appeal
DecidedFebruary 10, 2025
DocketG061912
StatusUnpublished

This text of Meikle v. County of Orange CA4/3 (Meikle v. County of Orange CA4/3) 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
Meikle v. County of Orange CA4/3, (Cal. Ct. App. 2025).

Opinion

Filed 2/10/25 Meikle v. County of Orange CA4/3

NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FOURTH APPELLATE DISTRICT

DIVISION THREE

CAROLE MEIKLE, Individual and as Personal Representative, etc., G061912 Plaintiff and Appellant, (Super. Ct. No. 30-2018- v. 00973047)

COUNTY OF ORANGE, OPINION

Defendant and Appellant.

Appeal from a postjudgment order of the Superior Court of Orange County, Theodore R. Howard, Judge. Affirmed. V. James DeSimone Law, V, James DeSimone and Ryann E. Hall, and Bohm Law Group and Zane E. Hilton, for Plaintiffs and Appellants. Lynberg & Watkins, Norman J. Watkins and S. Frank Harrell, for Defendant and Appellant. On May 6, 2017, the Orange County Coroner’s Office (Coroner’s Office) erroneously identified the body of a deceased male as belonging to Francis M. Kerrigan (“Frankie”) and informed his father Francis J. Kerrigan (Kerrigan) and his sister Carole E. Meikle (Meikle) that Frankie had died. After the body was buried, Frankie turned up alive. Kerrigan and Meikle (collectively Plaintiffs) sued respondent the County of Orange (County) for negligence, negligent misrepresentation, and intentional misrepresentation, seeking damages for their serious emotional distress. A jury returned special verdicts in Plaintiffs’ favor on all counts, and awarded Kerrigan $1.2 million 1 and Meikle $400,000. The County filed a post-trial motion for judgment notwithstanding the verdict (JNOV) and alternatively for a new trial as to all counts. The trial court granted a JNOV on the intentional misrepresentation claims only, but granted a new trial on the remaining claims and on the issue of damages. Plaintiffs appealed the grant of JNOV on the intentional misrepresentation claims and the grant of a new trial, and the County cross- appealed from the denial of JNOV on the other claims. Relying primarily on language in Thing v. La Chusa (1989) 48 Cal.3d 644 (Thing), the County contends that as a matter of law, plaintiffs cannot recover for emotional distress merely from learning about the death of a deceased family member. We disagree and conclude the referenced language is not applicable to the case here. Plaintiffs argue there was substantial evidence to support the

1 Kerrigan died while this appeal was pending, and Meikle, the executor of his estate, was substituted as the plaintiff on all his claims. For clarity, however, we will continue to refer to Kerrigan in the opinion. No disrespect is intended.

2 jury’s special verdicts on the intentional misrepresentation claims. We conclude, however, there was insufficient evidence to show scienter or intent to defraud, which are elements of the claims. Plaintiffs also argue the trial court abused its discretion in granting a new trial. As discussed below, we conclude the trial court provided valid reasons to support the grant of a new trial on the negligence-based claims and defer to its exercise of discretion. Accordingly, we affirm. STATEMENT OF THE FACTS I STIPULATED FACTS On May 6, 2017, at around 11:55 a.m., a Fountain Valley police officer called the Coroner’s Office to notify them of a death of an apparent homeless man who was found near a Verizon Wireless store located in Fountain Valley, California. The officer informed Senior Deputy Coroner David Ralsten that, while there was no exact identification of the deceased at that time, he believed the identity of the deceased was Frankie, based on his prior experiences with local law enforcement. Ralsten printed a copy of Frankie’s Department of Motor Vehicle (DMV) image record, which contained a photograph of Frankie, and brought it with him to the scene. Ralsten arrived at the store around 12:40 p.m., and investigated the reported death by examining the body of the deceased, examining the area, and taking photographs. Ralsten searched the body of the deceased, the deceased’s personal possessions, and the area around the scene where the body was discovered to ascertain any identifying information, but did not find any. Using the DMV record, Ralsten made visual comparisons with the deceased. Based on what he perceived as shared characteristics between the deceased and Frankie, Ralsten believed the

3 deceased was Frankie and identified the body as that of Frankie. At approximately 3:00 p.m. the same day, Kerrigan received a note from the Riverside County Sheriff’s Office directing him to call the Orange County Coroner’s Officer regarding his son Frankie. Shortly after receiving the note, he called the Coroner’s Office and spoke with Megan Meier, who informed him that his son was deceased. The body of the deceased was transported to the Coroner’s Office, where fingerprints were taken on May 6. The fingerprints were sent to the Federal Bureau of Investigation (FBI), the Department of Homeland Security, the State of California Department of Justice and local law enforcement databases for comparison with fingerprints in their databases. The results from the federal, state, and local databases were electronically sent back to the coroner’s computers on May 6 and May 7. The Coroner’s Office misconstrued the returned messages and concluded the fingerprints taken off the body did not return any hits, when a hit did come back for John Dean Dickens, not Frankie. The autopsy of the deceased was performed on May 9, and the body was released to the funeral home on May 9. An open-casket wake was held for Frankie’s immediate family on May 11. On May 12, the funeral was held, and the body interred. On May 23, Kerrigan received a phone call from a family friend who informed him that Frankie was alive. On May 30, a Kerrigan family representative notified the Coroner’s Office that Frankie was alive. On June 1, the Coroner’s Office informed the Kerrigan family representative that the deceased was John Dean Dickens. The body was exhumed on August 23. The County paid Kerrigan $20,558.59, which he acknowledged covered all expenses for the funeral, mass, and burial.

4 II TRIAL TESTIMONY A. Senior Deputy Coroner David Ralsten Ralsten testified that after receiving the call from Officer McCrae, he printed out the DMV record, which had a 2005 photo of Frankie and indicated his weight was 180 pounds at the time. When he arrived at the scene, he observed a wheelchair nearby. He also noted the remains weighed roughly 250 pounds. However, Ralsten never specifically informed anyone to follow up on the wheelchair or the weight of the deceased. Ralsten testified he observed similarities between the 2005 DMV photo of Frankie and the face of the deceased, including: “Both eyes are blue. The hair color was approximately the same. The chin shape. The fullness of the chin. . . . They both appeared to have a cleft in the chin. The width of the nose. The length of the nose. The set of the eyes. The set of the ears. And the hairline.” After his investigation at the scene, Ralsten returned to his office and began documenting his observations at around 2:30 p.m. Among the notes he inputted was: “Identification of [Frankie] by A. McCrae. Method: Driver’s License.” Ralsten pulled Frankie’s DMV and criminal records, and learned Frankie had been arrested two weeks earlier and his father was Kerrigan. Ralsten then left for his vacation, and was not present when the body was transported to the Coroner’s Office that evening. Ralsten knew fingerprints would be taken and sent to other agencies via the LiveScan program.

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Meikle v. County of Orange CA4/3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/meikle-v-county-of-orange-ca43-calctapp-2025.