Breaking Barriers to Justice
In practice, this means that the regulatory record is not background material. It is often the spine of the case. A facility cited by the California Department of Public Health (CDPH) for failure to report incidents of suspected abuse under Title 22 of the California Code of Regulations has not committed a paperwork violation — it has generated evidence of a pattern. That citation, combined with discovery into prior complaint files, internal investigation records, and corrective action plans, can establish the recklessness finding under Samantha B. before you ever get to contested facts about what happened between the patient and the employee. We have used exactly this approach to bring cases across a seven-figure threshold where the details of the assault itself were genuinely in dispute.
CDPH inspection records and any substantiated citations. Run every entity through the Secretary of State to identify parent companies, ownership structures, and affiliated facilities — because in healthcare systems, the entity you see is rarely the only entity with exposure. A facility operating under a corporate parent that owns twenty other licensed facilities has a different risk profile than a standalone operator, and that parent's knowledge of systemic issues is potentially in play. Identifying those layers early shapes both the defendant map and the coverage analysis. And invest in the client relationship. In institutional abuse cases involving dependent adults, the path from 'something happened' to a complete account is rarely linear. These clients are often still dependent on similar systems, deeply ashamed, or neurologically limited in how they can communicate what occurred.
Start this work before you draft a single word of the complaint. Pull the facility's licensing history. Check
57
Consumer Attorneys of California
FORUM July/August 2026
Made with FlippingBook - Online catalogs