1DCA Division 1 Oral Argument - 2026/4/1 - Apr 01, 2026

argument

1DCA Division 1 Oral Argument - 2026/4/1

California First District Court of Appeal 23 min 8 chapters transcribed 1 month ago official recording ↗

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What case is being heard in this oral argument and who are the parties?

Jim Hume 0:04

All right. The Court of Appeal, the state of California, First Appellate District, Division I is now in session. The Honourable Jim Hume is presiding with Justices, Kathleen Bainkey and Charles Smiley.

Unknown 0:18

Good morning and please be seated. And also with us this morning will be Justice Banke, who will be participating remotely, I believe. I don't know if that's been set up yet. Tata. Oh, here we go. Never mind. All right, so here we have the the the panelists, myself, Justice uh Banke by remote, and Justice Smiley to my left here. And uh thank you all for being here. Good morning. Uh we have one case on the can on the calendar this morning. It's Sandoval versus Acadia Healthcare Company. And if I can get an entry of appearance from both the council, I'd appreciate it.

Lacia Stadillo 1:04

Good morning, Your Honors Lacia Stadillo on behalf of Acadia Healthcare Company.

Unknown 1:08

Okay, thank you, Mrs. Stadillo.

John Williams 1:13

Good morning, Your Honors. John Williams on behalf of respondent Kimberly Sandoval.

Unknown 1:17

Okay, thank you very much. Thank you. And we'll start with you if you want to get us going. And we of course put out a tentative in this case and you reviewed it, so um you think we've got some things wrong, so just let's focus right on what you think we didn't get right. Your Honors. Good morning. Good morning. And may it please the court. I'd like to reserve five minutes of my time for rebuttal. Sure, you may do that.

How does counsel for Acacia Healthcare request entry of appearance and introduce their opening remarks?

Unknown 1:40

All right. Your Honors, we appreciate the Court's tentative ruling in this case. Because my time is limited today. I plan to focus on three topics in the tentative, but if the court is interested, I'm happy to answer other questions about any issues that were raised in the appellate briefing. Thank you. The topics I plan to address include the lack of substantial evidence supporting the jury's finding that understaffing caused Mr. Pinto's injury. The inadmissibility of the elevenths medical cost summary. which was not authenticated, contains multiple layers of hearsay. was not produced during discovery. And was erroneously admitted. As a judicial exhibit after the close of evidence. And finally, I'll address the in inadmissibility of expert testimony.

Unknown 2:28

on peer issues of law regarding the governing regulations. So turning to my first point, your honours. The tenative opinion holds that substantial evidence supports a finding that understaffing caused Mr. Pinto's injury. We disagree. Plaintiff stipulated and the jury was instructed. Та Нерс Ривера і АРАРЕ ХЕЛЬКЕР проваджує. including those who ordered thirty minute monitoring were not negligent. Well but but but why is that inconsistent with what what the what the a finding of negligence is. I mean the the fact no one disagrees that the people who are on duty that day did a good job or did the best job they could do. I think the disagreement is is was there enough people on duty?

Unknown 3:12

And the question and the answer to that is no there there wasn't because one of the nurses was missing. Well, even if A nurse was missing and there there was negligence on the part of the facility because it was understaffed. Plaintiffs still had to prove that understaffing caused plaintiff's injury in this case. Well why couldn't why wasn't that a jury determination? Because there was no evidence of any causation that could have prevented his injury. So the n but the nurse testified that she would have given more attention to Uh to Mr. Pinto if if there had been if she had if she'd been able to, but she wasn't able to because she had to run around and go on both sides of the campus all day long. Your Honor, we believe that the o the tentative overstates the exchange between Nurse Rivera and plaintiff's counsel on that point.

Unknown 3:57

So plaintiffs counsel asked Nurse Rivera. If you have a level one, as you did in this case, Mr. Pinto and Canyon View. You likely would have been spending a lot more time in Canyon View to keep tabs on him, correct? She responded correct. I would have been back and forth to the nurse station. And to Canyon View to do my rounds. This does not establish that different care would have been provided.