Laura and Richard Crowell (plaintiffs) were married. Laura suffered from agoraphobia and other panic disorders. Laura sought treatment from College Hospital, Inc. (Hospital) (defendant). Laura met Hospital employee Robert Berry during her treatment and became involved in an extramarital affair with him. Laura claimed both that Berry manipulated her and that the Hospital’s therapists encouraged the relationship. Berry eventually ended the affair. Laura suffered a breakdown and was admitted to a different psychiatric institution. Laura and Richard sued the Hospital. In the complaint, Laura alleged that the Hospital knew about: (1) a prior relationship between Berry and another patient and (2) the relationship between Berry and Laura. The complaint also alleged that the Hospital did not warn Laura about Berry’s propensity for relationships with patients. The Crowells filed a motion to amend their complaint to state a punitive-damages claim. The proposed amended complaint did not contain any additional facts, but it did include a declaration from Laura swearing to the same facts that were in the original complaint. The trial court granted the motion to amend. The Hospital appealed to the California Court of Appeal, which affirmed. The Hospital then petitioned the California Supreme Court for review.