USCF Benioff Children’s Hospital Oakland v. Superior Court of California, City of Alameda

Thirteen-year-old Jahi McMath (plaintiff) went into cardiac arrest after a surgical procedure at USCF Benioff Children’s Hospital Oakland (Children’s Hospital) (defendant). Two medical professionals determined that McMath’s brain function had irreversibly ceased, and they pronounced her dead in accordance with California’s Uniform Determination of Death Act. A death certificate was issued. McMath’s mother, Latasha Winkfield (plaintiff), petitioned to compel Children’s Hospital to provide medical treatment to McMath, whom Winkfield asserted was still alive. In a probate action, a court-appointed specialist in child neurology confirmed McMath’s irreversible brain death, as did the two physicians who made the initial determination. The probate court issued a final order on the subject. Winkfield did not challenge the probate court’s findings or final order, but she did initiate a series of civil proceedings on McMath’s behalf to collaterally attack the determination of death. At various points, Winkfield claimed that changed circumstances warranted reconsideration of McMath’s medical state. Winkfield’s civil actions included a personal-injury action with which the Alameda County Superior Court allowed Winkfield to proceed. Children’s Hospital petitioned the California Court of Appeal for a writ of mandate to preclude Winkfield’s efforts to overturn McMath’s death certificate on grounds of collateral estoppel, which was denied. Children’s Hospital then petitioned the California Supreme Court for review.