Inland Empire Health Plan v. Superior Court

This case concerns the tort liability of a public entity Medi-Cal health maintenance organization (HMO) and a private independent practice association (IPA) for injuries negligently inflicted on a plan member by contracting physicians. The causes of action are: (1) negligent credentialing; and (2) medical malpractice, alleging that (a) the physicians who caused the injury were ostensible agents of the defendants, and (b) the defendants were vicariously liable for the referring physician’s negligent referral to the physicians who caused the injury.

Petitioners, defendants in the underlying action, petitioned this court for a writ of mandate directing the trial court to vacate its orders denying defendants’ motions for summary judgment and enter new orders granting defendants’ motions for summary judgment. As explained below, we conclude that the trial court erred when it denied the motions and therefore grant the writ of mandate as to both petitioners.

The Facts

Inland Empire Health Plan (IEHP) is a public entity HMO. It operates under a joint powers agreement between Riverside and San Bernardino Counties to provide health coverage for Medi-Cal participants. IEHP…