College Hospital, Inc. v. Superior Court

Laura Crowell (plaintiff), a psychiatric patient at College Hospital (defendant), had an affair with hospital employee Robert Berry and alleged the hospital knew of Berry's history with another patient and encouraged or failed to warn her about the relationship; when Laura and her husband Richard sought to amend their complaint to add a punitive-damages claim under Code of Civil Procedure § 425.13(a), their motion included only a declaration repeating the original complaint's facts, with no new evidence that a hospital administrator knowingly approved the relationship. The trial court granted the amendment, and the court of appeal affirmed.