In Flowers v. Torrance Memorial Hospital Medical Center (1994) 8 Cal.4th 992, the plaintiff fell off the side of a gurney on which the side rail had not been raised by the attending nurse. The Court of Appeal reversed the summary judgment in favor of the defendant hospital and nurse, the majority agreeing "that defendants had negated any 'professional negligence,'" but finding "the pleadings 'broad enough to encompass a theory of liability for ordinary as well as professional negligence' because the manner of her in jury did not involve a breach of duty to provide professional skill or care." (Flowers, supra, 8 Cal.4th at p. 996, fn. omitted.) The Supreme Court reversed and remanded, holding that "the same factual predicate cannot give rise to two independent obligations to exercise due care according to two different standards because this is a legal impossibility: a defendant has only one duty, measured by one standard of care, under any given circumstances." (Id. at p. 1000.) In doing so, Flowers cited Gopaul v. Herrick Memorial Hosp. (1974) and Murillo v. Good Samaritan Hospital (1979) noting they had "addressed the question of whether a patient's fall from a hospital bed or gurney constituted 'ordinary' or 'professional' negligence." (Flowers, supra, 8 Cal.4th at p. 999.) But "because the question was not squarely presented, Flowers declined to resolve the conflict between Murillo ... and Gopaul ... on the question of whether a patient's fall from a hospital bed or gurney implicates 'professional' or 'ordinary' negligence in a statutory context. However, to the extent either decision may be inconsistent with the analysis herein, it was disapproved." (Id. at p. 1002, fn. 6.)