January 31, 2024

Shalghoun v. North Los Angeles County Regional Center, Inc.

Regional centers develop individually tailored plans for developmentally disabled persons (“consumers”) and enter into contracts with facilities that implement these support plans. A regional center placed a consumer at a residential facility, but the facility could not provide the level of care required and requested the consumer be relocated. While the regional center was arranging the relocation, the consumer attacked the facility’s administrator. The residential facility administrator sued the regional center for negligence. The trial court granted the regional center’s motion for summary judgment. Plaintiff appealed.

The Court of Appeal affirmed, holding that the regional center did not have a special relationship with the consumers giving rise to a duty of care owed to employees of residential facilities because (1) the regional center lacked the ability to control the consumer; (2) even if the regional center had a duty to control the consumer, its duty would be to protect the consumer rather than the residential facility and its employees; (3) even if the regional center had a duty to protect plaintiff, imposing liability on the regional center is against public policy.