Marika Delgado v. Manor Care of Tucson

Summary

The court held that an actionable claim for abuse of a vulnerable adult under APSA requires proof of a vulnerable adult, an injury, abuse causing the injury, and a caregiver who caused it. It disapproved the prior four-part test because it added requirements not found in the statute and improperly narrowed APSA's remedial purpose. Applying the statutory elements, the court held that triable issues required reversal of summary judgment. No separate opinions were filed.