Simms

BACKGROUND

Bear Valley is a local health care district organized under Health and Safety Code

section 32000 et seq. On December 8, 2017, Simms was injured in a fall and sought

treatment at Bear Valley’s emergency room. In December 2017 and January 2018,

2 Simms went to appointments with several Bear Valley medical providers to obtain

additional treatment for continuing pain from his injuries.

Simms was not satisfied with his experience at the follow-up appointments. On

two occasions—December 26, 2017, and January 26, 2018—he verbally “file[d] a

grievance” with Bear Valley, complaining that the providers who saw him had the

perception that he was trying to obtain drugs on false pretenses and thus were refusing to

investigate and treat his ongoing, chronic pain. Bear Valley responded to these

complaints with a letter dated January 30, 2018, explaining what the providers had

observed about Simms’s behavior during three visits. Several appointments in March

and April 2018 also did not meet Simms’s expectations. On April 24, 2018, Bear Valley

sent Simms a “formal notice” that Bear Valley would “no longer serve as [his] primary

care provider due to unresolved differences…