Holland v. Silverscreen Healthcare, Inc.: MICRA § 1295 Arbitration Does Not Reach Wrongful Death Claims Predicated on Custodial Neglect at Skilled Nursing Facilities

Introduction

In Holland v. Silverscreen Healthcare, Inc. (Supreme Court of California, Aug. 14, 2025), the Court addressed a recurring and consequential question at the intersection of medical arbitration under MICRA and wrongful death litigation against long-term care providers. The plaintiffs, parents of a dependent adult who died while residing at a 24-hour skilled nursing facility, brought survivor claims (including under the Elder Abuse and Dependent Adult Civil Protection Act) and a separate wrongful death action alleging neglect. The decedent had signed a MICRA-compliant arbitration agreement on admission. The key issue was whether, under Ruiz v. Podolsky (2010) 50 Cal.4th 838, that patient-provider arbitration agreement compels heirs to arbitrate their wrongful death claim when the alleged misconduct is custodial neglect rather than professional medical negligence.

The trial court compelled arbitration of the survivor claims but denied arbitration for the heirs’ wrongful death claim. The Court of Appeal reversed, reading the allegations—falls, infections, and understaffing—as sounding in “professional negligence,” thus bringing the claim within Ruiz and Code of Civil Procedure § 1295. The California Supreme Court unanimously reversed the Court of Appeal, holding that Ruiz binds heirs only when the wrongful death claim alleges medical malpractice as defined in § 1295, not when the claim is predicated on custodial neglect. The Court remanded with instructions to allow plaintiffs to amend to clarify the nature of their wrongful death theory.

Summary of the Opinion

The Court, per Justice Kruger, reaffirmed the baseline rule: heirs ordinarily cannot be compelled to arbitrate unless they agreed to arbitration. Ruiz creates a narrow, statutory exception for wrongful death claims grounded in medical malpractice as defined in MICRA’s arbitration provision (Code Civ. Proc., § 1295). Because skilled nursing facilities provide both medical and custodial services, not every claim against them is “professional negligence.” The opinion draws a decisive line:

• Section 1295 applies only to disputes about whether “medical services” were improperly rendered—i.e., professional negligence.
• Wrongful death claims alleging custodial neglect—failures to provide basic care such as nutrition, hydration, safety, or supervision—fall outside § 1295 and therefore outside Ruiz.
• Allegations of injuries from falls or infections may be medical or custodial depending on the nature of the duty breached; they are not categorically “professional negligence.”

Finding the complaint sparse and unclear as to whether the wrongful death theory sounded in medical malpractice or custodial neglect, the Court directed that plaintiffs be allowed to amend to specify. The Court thus:

• Reversed the Court of Appeal’s order compelling arbitration of the wrongful death claim, and
• Remanded with instructions to allow amendment and to determine arbitrability in light of the clarified allegations.

The survivor claims remained ordered to arbitration; that ruling was not before the Court.

Analysis

Precedents Cited and Their Influence

• Ruiz v. Podolsky (2010) 50 Cal.4th 838:
  Established that a patient’s § 1295-compliant agreement to arbitrate medical malpractice claims may bind heirs’ wrongful death claims if the agreement manifests an intent to do so, because § 1295’s definition of “professional negligence” includes wrongful death. Holland reaffirms Ruiz but limits its reach to claims truly about “medical services” as defined in § 1295. Ruiz is not a blanket rule compelling arbitration for all wrongful death claims against health care providers.
• Reigelsperger v. Siller (2007) 40 Cal.4th 574:
  Recognized MICRA’s purpose to reduce costs and facilitate arbitration of malpractice disputes. Holland harmonizes cost-control goals with statutory limits by confining arbitration to medical malpractice disputes, as § 1295 requires.
• Flores v. Presbyterian Intercommunity Hospital (2016) 63 Cal.4th 75:
  Articulated the “integrally related” test: professional negligence under MICRA exists when the duty breached arises by virtue of being a health care provider and is integral to providing medical care (e.g., maintaining medical equipment). Not every injury in a health facility is professional negligence (e.g., a waiting-room chair collapse). Holland uses this functional approach to separate medical from custodial duties in skilled nursing facilities.
• Delaney v. Baker (1999) 20 Cal.4th 23; Covenant Care, Inc. v. Superior Court (2004) 32 Cal.4th 771:
  Distinguished Elder Abuse Act “neglect” (failures to meet basic needs, regardless of professional status) from MICRA “professional negligence” (substandard performance of medical services). Holland leans on these cases to emphasize that failures in staffing, hydration, nutrition, safety, or general monitoring are typically custodial, not medical.
• Winn v. Pioneer Medical Group, Inc. (2016) 63 Cal.4th 148:
  Recognized the “dual capacity” reality of institutions that both treat and caretake, reinforcing that custodial and medical functions are conceptually distinct. Holland applies this dual-capacity understanding to skilled nursing facilities.
• Horwich v. Superior Court (1999) 21 Cal.4th 272; Victoria v. Superior Court (1985) 40 Cal.3d 734:
  Wrongful death claims are independent and usually not bound by a decedent’s arbitration clause. Ruiz carved an exception only for medical malpractice disputes—to which Holland returns the law.
• Johnson v. Open Door Community Health Centers (2017) 15 Cal.App.5th 153:
  Highlighted the difference between the medical standard of care and the general duty of care; Holland adapts this distinction to draw the § 1295 line.
• Avila v. Southern California Specialty Care, Inc. (2018) 20 Cal.App.5th 835; Valentine v. Plum Healthcare Group, LLC (2019) 37 Cal.App.5th 1076; Daniels v. Sunrise Senior Living, Inc. (2013) 212 Cal.App.4th 674; Hearden v. Windsor Redding Care Center, LLC (2024) 103 Cal.App.5th 1010:
  Post-Ruiz appellate decisions that declined to compel arbitration of wrongful death claims against long-term care facilities where the “primary basis” was custodial neglect. Holland aligns with this line and confirms the core premise: the applicability of § 1295 turns on the nature of the duty breached.
• Quiroz v. Seventh Ave. Center (2006) 140 Cal.App.4th 1256:
  Held that only victims (or successors) can assert Elder Abuse Act remedies; heirs cannot assert those enhanced remedies in their own name. Holland limits Quiroz to its standing context and rejects arguments that heirs cannot premise wrongful death on “neglect” as defined in the Act. Heirs may sue for wrongful death under § 377.60 and may draw on statutory definitions of wrongfulness without claiming Elder Abuse Act remedies.
• Norgart v. Upjohn Co. (1999) 21 Cal.4th 383; B.B. v. County of Los Angeles (2020) 10 Cal.5th 1 (conc. opn. of Liu, J.):
  Clarify the nature of wrongful death as a statutory claim requiring an underlying wrongful act or neglect. Holland recognizes that the Elder Abuse Act’s “neglect” can supply that underlying wrong even when enhanced Act remedies are not sought.

Legal Reasoning

The Court’s reasoning proceeds from statutory text and settled doctrine:

• Textual anchor in § 1295: The statute’s mandatory arbitration clause applies to disputes over “medical malpractice,” defined as whether “any medical services rendered under this contract” were unnecessary, unauthorized, or improperly performed. Section 1295(g)(2) defines “professional negligence” as negligent acts or omissions by a health care provider “in the rendering of professional services.”
• Narrow scope of Ruiz: Ruiz permits heirs to be bound only when the wrongful death dispute qualifies as “professional negligence” under § 1295. Holland rejects any reading that would treat all wrongful death claims against licensed facilities as medical malpractice by default.
• Dual-capacity framework: Skilled nursing facilities “wear multiple hats.” When they provide medical services, claims may be subject to § 1295; when they perform custodial functions—feeding, hydrating, assisting with hygiene and mobility, ensuring safe premises—the duties are not owed by virtue of being a medical provider, and disputes fall outside § 1295. This echoes Flores (integral medical duties) and Delaney/Covenant Care (custodial neglect).
• Falls and infection are not categorically medical: A fall or infection might arise from negligent medical judgment (e.g., a flawed clinical care plan) or from custodial failings (e.g., insufficient supervision during transfers, failure to monitor and escalate obvious symptoms). The fact pattern controls. Therefore, courts must examine whether the alleged duties arise from medical services or from general custodial responsibilities.
• Procedural posture—pleading clarity: Because the complaint here was “spare” and did not connect the injuries (falls and infections) to a specifically medical or custodial breach, the Court refused to compel arbitration on an unclear record. A motion to compel arbitration is about forum selection, not about testing substantive sufficiency. Trial courts should permit amendment where the medical versus custodial nature of the claim is unclear.
• Quiroz does not bar wrongful death based on “neglect”: While heirs lack standing to recover Elder Abuse Act’s enhanced remedies in their own name, they may pursue wrongful death under § 377.60 and may premise the “wrongful act or neglect” element on conduct amounting to “neglect” as defined by the Elder Abuse Act. The heirs’ reliance on that definition does not convert the claim into an Elder Abuse Act cause of action or preclude it under Quiroz.

Impact and Practical Implications

Holland is a significant recalibration of the scope of arbitration under MICRA in the long-term care context. Its practical effects include:

• Narrowing of compulsory arbitration against heirs: Health care defendants cannot automatically compel heirs’ wrongful death claims to arbitration under Ruiz merely because the decedent signed a § 1295 agreement. The defendant must show the wrongful death claim is a dispute about the rendering of medical services within § 1295.
• Clearer line-drawing for skilled nursing facilities: Allegations centered on understaffing, failure to assist with basic activities of daily living, inadequate supervision, poor facility maintenance, lack of hydration/nutrition, or failure to protect from routine hazards will generally be custodial and thus litigable in court. By contrast, claims anchored in clinical judgments or execution of medical plans may fall within § 1295.
• Hybrid proceedings more likely: Survivor claims (often including Elder Abuse Act and negligence claims) may be compelled to arbitration when covered by broader admission agreements, while independently asserted wrongful death claims by heirs may proceed in court if custodial. Parties should prepare for coordinated but bifurcated litigation.
• Pleading practice guidance:
  • Plaintiffs should plead with specificity how alleged acts/omissions were custodial (or medical), tying mechanisms of injury (falls, infections) to the nature of the duty breached.
  • Defendants seeking arbitration should identify allegations showing medical decision-making or clinical protocols (e.g., risk assessment methodology, medication management, clinical orders) rather than general staffing or supervision shortfalls.
  • Trial courts should permit targeted amendment where the medical/custodial line is unclear before ruling on arbitrability.
• Contract drafting and enforcement: Even if admission agreements include broad “binding on heirs” language, § 1295’s statutory limits control. Agreements cannot expand arbitrability beyond disputes about medical services as defined by statute. Defense counsel should pair contract enforcement with a merits-based showing that the claim is indeed “professional negligence.”
• Substantive law continuity: Holland synthesizes Flores, Delaney, Covenant Care, and Winn, reaffirming the dual-capacity framework and the functional “integrally related to medical care” test. It aligns with Avila/Valentine/Daniels/Hearden, giving those appellate decisions a strong Supreme Court imprimatur.

Complex Concepts Simplified

• Ruiz exception: Normally, heirs aren’t bound by a decedent’s arbitration agreement. Ruiz carved out an exception for medical malpractice disputes under § 1295: if a patient agreed to arbitrate malpractice claims, heirs may be compelled to arbitrate wrongful death claims that are truly medical malpractice.
• “Professional negligence” under § 1295: Negligence “in the rendering of professional services” by a health care provider. Think clinical decisions and acts integral to providing medical care. Not every harm in a health facility is professional negligence.
• Custodial neglect (Elder Abuse Act): Failing to meet basic needs and protect from hazards—assistance with hygiene, feeding, hydration, mobility, and safety—regardless of professional status. This is generally not “professional negligence” for MICRA arbitration purposes.
• Dual capacity: Skilled nursing facilities both treat (medical) and caretake (custodial). The same entity owes different kinds of duties. Whether § 1295 applies depends on which capacity is implicated by the allegations.
• “Integrally related” test (Flores): Ask whether the duty arises by virtue of being a health care provider and is integral to medical care. Maintaining medical equipment used in treatment is integral; keeping a waiting room chair safe is not.
• Wrongful death vs. survivor claims: Wrongful death (§ 377.60) is an independent claim for heirs’ own losses; survivor claims continue the decedent’s causes of action. Heirs may borrow statutory definitions of “wrongful acts” (such as “neglect” in the Elder Abuse Act) without claiming the Act’s enhanced remedies.

Applications and Examples

The following illustrations reflect Holland’s framework for skilled nursing facilities:

• Likely custodial (not arbitrable under § 1295):
  • Failure to assist with transfers, toileting, or ambulation leading to a fall.
  • Chronic understaffing resulting in missed meals/hydration or failure to reposition, causing malnutrition, dehydration, or pressure injuries.
  • Failure to monitor residents and escalate obviously deteriorating conditions to medical personnel.
  • Unsafe premises or equipment unrelated to clinical care (e.g., broken handrails, inadequate lighting).
• Potentially medical (arbitrable under § 1295 if tied to clinical services):
  • Negligent clinical assessment and care plan for fall risk (e.g., contraindicated sedatives, omitted bed/chair alarms specified in a clinical protocol).
  • Improper wound care orders or execution (e.g., negligent debridement technique; failure to follow prescribed wound protocol).
  • Negligent infection diagnosis/treatment decisions (e.g., failure to order indicated labs/imaging; improper antibiotic selection or dosing).

Procedural Guidance on Remand (and for Future Cases)

• For plaintiffs: Plead the “how” and “why.” Connect the injury mechanism (falls, infections) to custodial lapses (e.g., missed supervision, inadequate staffing, failure to provide hydration) if the theory is nonmedical neglect. If the theory includes medical malpractice, separate and specify those allegations.
• For defendants: To compel arbitration under Ruiz, identify allegations that hinge on clinical judgment or execution of medical services, not just general custodial failings. Cite to care plans, orders, clinical protocols, and provider decision-making.
• For trial courts: Where the complaint is unclear, allow targeted amendment before determining arbitrability; the objective is correct forum selection, not early merits adjudication. Consider limited evidentiary submissions if necessary to understand whether the gravamen is medical or custodial.

Conclusion

Holland delivers a clear and important clarification: the Ruiz exception to the general rule against compelling non-signatory heirs to arbitrate applies only to wrongful death claims that qualify as medical malpractice under § 1295. In the skilled nursing facility context—where medical and custodial roles coexist—courts must examine the nature of the duty allegedly breached. Failures in basic care and safety are custodial and fall outside § 1295; clinical misjudgments in rendering medical services may fall within it. The decision aligns with Delaney, Covenant Care, Flores, and leading appellate decisions such as Avila and Valentine, and cabins any overbroad application of Ruiz.

Practically, Holland will lead to more careful pleading, more focused motions to compel arbitration, and, in some cases, hybrid proceedings where survivor claims proceed in arbitration and wrongful death claims proceed in court. Above all, it restores statutory fidelity: MICRA arbitration agreements cannot be used to funnel non-medical neglect claims into arbitration merely because the defendant is a health care provider or because the decedent signed a § 1295-compliant agreement. Courts must honor the statutory line between medical services and custodial care—and Holland shows exactly how to draw it.