Snover v. Gupta (Nov. 18, 2025, No. A172568) __ Cal.App.5th __ [2025 WL 3215132]
The guardian of Adria Snover sued Dr. Aruna Gupta, Dr. Neel Pandya, and Riverside Community Hospital after medical complications during a cesarean section left her in a permanent coma. Before trial, Snover settled separately with Dr. Pandya and with the hospital. The hospital’s settlement allocated $250,000 to Snover’s son in exchange for a waiver of his right to bring a future wrongful death claim. At trial against Dr. Gupta, the jury awarded Snover almost $7.5 million in economic damages and $10 million in noneconomic damages; the jury allocated 15 percent fault to Dr. Gupta. To prepare a judgment, the trial court reduced the verdict to account for the pretrial settlements and Dr. Gupta’s percentage of fault. The court calculated Dr. Gupta’s noneconomic liability by first reducing the noneconomic damages award to $250,000 (the then-existing MICRA cap) and then reducing that sum to $37,500 (Dr. Gupta’s 15 share of fault). In calculating economic damages, the trial court followed Mayes v. Bryan (2006) 139 Cal.App.4th 1075 by calculating the ratio of economic damages to total damages (here, economic damages plus $37,500), and then applying that percentage to the pretrial settlement amounts to determine the amount of setoffs to apply to the total damages. The court included the $250,000 allocated to Snover’s son in its setoff calculation. Snover appealed.
The Court of Appeal affirmed the trial court’s sequencing and result. It held that, consistent with Gilman v. Beverly California Corp. (1991) 231 Cal.App.3d 121 and Rashidi v. Moser (2014) 60 Cal.4th 718, the trial court correctly applied the MICRA cap before apportioning liability for noneconomic damages because all defendants were healthcare providers covered by MICRA. The court explained that reversing the order of operations—i.e., first multiplying noneconomic damages by a defendant’s percentage of fault and then capping noneconomic damages at $250,000 under MICRA—would improperly inflate the noneconomic damages award. The court next explained that, under Mayes, the trial court must apply the MICRA cap before determining the portion of pretrial settlements setoff against economic damages because all defendants were protected by MICRA. This prevents skewed allocation of settlement dollars to noneconomic damages (thereby reducing the amount of settlements offsetting the economic damage award) and ensures that settlement allocations are consistent with defendant’s MICRA-capped exposure. Finally, the court rejected Snover’s argument that, when valuing her settlement with the hospital, the trial court should have excluded the $250,000 allocated to her son’s future wrongful death claim, reasoning that plaintiff’s son was not a party to the settlement and Snover failed to prove the amount disbursed to her son was “arrived at in a sufficiently adversarial proceeding that it should be deducted from the hospital’s settlement with her.”
