Regional Medical Center of San Jose v. County of Santa Clara CA6

Filed 7/30/24 Regional Medical Center of San Jose v. County of Santa Clara CA6 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

SIXTH APPELLATE DISTRICT

REGIONAL MEDICAL CENTER OF H050491 SAN JOSE et al., (Santa Clara County Super. Ct. No. 20CV374597) Plaintiffs and Appellants,

v.

COUNTY OF SANTA CLARA,

Defendant and Respondent.

THE COURT1 A dispute arose between appellants Regional Medical Center of San Jose and Good Samaritan Hospital (Hospitals) and respondent County of Santa Clara (County), doing business as Valley Health Plan (VHP), over reimbursement of emergency and post- stabilization services the Hospitals provided to patients insured through VHP. The trial court entered judgment in favor of the County after sustaining the County’s demurrer to the operative complaint without leave to amend, in part on the theory that the County had immunity from the Hospitals’ claims under the Government Claims Act (Gov. Code, § 810 et seq.). After the Hospitals appealed, the California Supreme Court issued its opinion in County of Santa Clara v. Superior Court (2023) 14 Cal.5th 1034 (Santa Clara), holding that the Government Claims Act does not immunize the County from a

1 Before Greenwood, P. J., Bamattre-Manoukian, J. and Wilson, J.

quantum meruit claim to enforce a statutory duty of reimbursement. Following this ruling, the parties jointly moved for summary reversal of the judgment to allow the Hospitals to proceed in the trial court consistent with the holding in Santa Clara. We grant the motion and reverse the judgment pursuant to the stipulation of the parties. I. PROCEDURAL BACKGROUND After the trial court sustained the County’s demurrers to the original and first amended complaint with leave to amend, the Hospitals filed the operative second amended complaint, alleging causes of action for breach of implied contract related to both emergency services and post-stabilization services, breach of contract by assignment, violation of several provisions of the Health and Safety Code and Code of Civil Procedure, and declaratory relief.2 Relevant to this appeal, the Hospitals alleged that the County had failed to reimburse them the “reasonable and customary value” of the services they rendered to patients enrolled in VHP, as required by the Knox-Keene Act (Health & Saf. Code, § 1340 et seq.).3 The County demurred to the second amended complaint, arguing in part that the Hospitals did not state claims for relief for the two causes of action for breach of implied