Klean W. Hollywood, LLC v. Superior Court of L. A. Cnty.

*170 Petitioner Klean W. Hollywood, LLC (Klean), a voluntary drug abuse treatment facility, was sued by real party Langston Jackson, who had enrolled at the facility to obtain treatment for drug addiction. Jackson blamed Klean for the injuries he suffered after smuggling heroin into his room and injecting it late one night. Jackson claimed that Klean was negligent in failing to prevent him from obtaining heroin and failing to discover him unconscious in his room until the next morning. Klean moved for summary judgment, contending that the common law doctrine of unclean hands precluded Jackson, or anyone who engages in the illegal acts of buying and using illicit drugs, from pursuing a negligence claim. Klean further contended that the Drug Dealer Liability Act ( Health & Saf. Code, § 11700, et seq., DDLA or the Act)-which permits users of certain illegal controlled substances, under limited circumstances, to pursue claims against providers of such substances-prohibits drug users from pursuing claims against parties other than the drug dealers described in the Act. 1 Although we conclude that the DDLA does not categorically preclude claims against third parties, we hold that on the…