California Supreme Court Watch

#23-156 Capito v. San Jose Healthcare System LP, S280018. (H049646; nonpublished opinion; Santa Clara County Superior Court; 20CV366981.) Petition for review after the Court of Appeal affirmed the judgment in a civil action. This case presents the following issue: Does a hospital have a duty to disclose emergency room fees to patients beyond its statutory duty to make its chargemaster publicly available?

Petition for review granted: 7/26/2023

Case fully briefed: 1/18/2024

Cause argued and submitted: 10/09/2024

Opinion filed; judgment affirmed: 12/23/2024

See the Court of Appeal Opinion.

See the Petition for Review.

See the Oral Argument.

See the California Supreme Court Opinion.  (Capito v. San Jose Healthcare System LP (2024) __ Cal.5th __.)

“The question here is whether hospitals have a duty, beyond what is required by the relevant statutory and regulatory scheme, to notify emergency room patients that they will be charged EMS fees….

We affirm the Court of Appeal’s judgment and hold that hospitals do not have a duty under the UCL or CLRA, beyond what is required by the statutory and regulatory scheme, to disclose emergency room EMS fees. We also dismiss as moot Capito’s appeal from the trial court’s order striking her class
allegations. We disapprove Torres [v. Adventist Health System/West (2022)] 77 Cal.App.5th 500 and Naranjo [v. Doctors Medical Center of Modesto, Inc. (2023)] 90 Cal.App.5th 1193 to the extent they are inconsistent with this opinion.”

Justice Liu authored the opinion of the Court, in which Chief Justice Guerrero and Justices Corrigan, Kruger, Groban, Jenkins, and Evans concurred.