Easton v. Sutter Coast Hospital

In Easton v. Sutter Coast Hospital (2000) 80 Cal.App.4th 485, cert. den. 531 U.S. 1084, 148 L. Ed. 2d 686, 121 S. Ct. 790 (Easton I), the Court construed this provision to confer a broad and absolute immunity for persons who provide access to the victims of suspected abuse. ( Easton I, supra, 80 Cal.App.4th at pp. 488-489, 495-496.) The Court found that the paramedics who entered the Crescent City residence to remove Winchester to the hospital enjoyed an absolute immunity against claims of trespass and false imprisonment based on their entry of the home without the Eastons' consent. ( Id. at pp. 495-496.) In the case before us, we conclude that the same statute also provides absolute immunity to the sheriff's deputies who entered the home without a warrant in order to allow those paramedics to remove Winchester. As the Court explained in Easton, it would undercut the ultimate goal of the Act if it did not protect both those who report suspected elder abuse and those who intervene in order to protect the victims of suspected elder abuse. ( Easton, supra, 80 Cal.App.4th at p. 495; see 15600, subd. (i).) The Eastons raise several objections to the application of this provision of the Act. First, they argue that chapter 12 of the Act cannot constitute a basis for immunity because it had not been adopted in Del Norte County and because the county did not comply with the provisions contained in that chapter. (See 15700-15755.) However, this argument is inapplicable to our case, as the statutory immunity set out in section 15634 is contained in chapter 11 of the Act. (See 15600-15660.)