Carlton v. Superior Court

In Carlton v. Superior Court (1968) 261 Cal.App.2d 282, the plaintiff sued the defendant for personal injuries arising from the defendant's alleged negligent operation of an automobile. Although the defendant specifically denied in his answer that he was intoxicated while driving, he did not tender the issue of his alleged intoxication within the meaning of the patient-litigant exception. (Id. at p. 289.)