Fall Off Bed In Hospital Ordinary Negligence Governed By The Two-Year Statute Of Limitations.

A patient brought an action against a hospital for general negligence and premises liability after a bed rail collapsed causing her injuries when she fell to the floor nearly two years earlier. The trial court dismissed the action, ruling the action was one for professional negligence subject to the one-year statute of limitations [Code of Civil Procedure section 340.5]. The appellate court reversed, holding the action sounded in ordinary negligence subject to the two-year statute of limitations [Code of Civil Procedure section 335.1].  Catherine Flores v. Presbyterian Intercommunity Hospital  (Cal. App. Second Dist., Div. 3;  February 27, 2013) 213 Cal.App.4th 1386.