Siskiyou Hospital, Inc. v. County of Siskiyou

Siskiyou Hospital, Inc. v. County of Siskiyou (Feb. 25, 2025, C097671, C098311) ___ Cal.App.5th ___ [2025 WL 601168]

County violates no ministerial duty by sending 5150 patients with mental (but not physical) health disorders to an acute hospital’s emergency department.

Siskiyou Hospital, Inc., doing business as Fairchild Medical Center (Fairchild), sued the County of Siskiyou, challenging the County’s practice of bringing individuals with psychiatric emergencies to its emergency department under section 5150 of the Lanterman-Petris-Short (LPS) Act (Welf. & Inst. Code, § 5000 et seq.). Section 5150 provides that persons who pose a danger to themselves or others because of a mental disorder may be taken to “a facility designated by the county for evaluation and treatment and approved by the State Department of Health Care Services” or an acute care hospital. Fairchild sought an order preventing the County from bringing 5150 patients to its emergency department and requiring those persons to be held for up to 72 hours when they require specialty mental health services and treatment but not any emergency care for a physical ailment. Fairchild also sought damages for breach of an implied contract to pay Fairchild’s full billed charges for its services to the 5150 patients and a traditional writ of mandate, alleging violations of the LPS Act, section 17000 of the Welfare and Institutions Code, Medicaid laws, disability discrimination laws, and mental health parity laws. The trial court sustained the County’s demurrers without leave to amend and denied Fairchild’s motion for a preliminary injunction. Fairchild appealed.

The Court of Appeal affirmed the trial court’s judgment of dismissal. The court held that, because Fairchild’s complaint identified no mandatory or ministerial duty that the County had failed to perform, a writ of mandate was unavailable; and no alleged fact supported an implied agreement that the County would pay Fairfield’s full billed charges. The court dismissed as moot Fairchild’s appeal from the denial of injunctive relief because no viable cause of action supported its request for a preliminary injunction.

The bulletin describing this appellate decision was originally prepared for the California Society for Healthcare Attorneys (CSHA) by H. Thomas Watson, Peder K. Batalden, and Lacey Estudillo at the appellate firm Horvitz & Levy LLP, and is republished with permission.

For more information regarding this bulletin, please contact H. Thomas Watson, Horvitz & Levy LLP, at 818-995-0800.

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