Jarman v. HCR ManorCare, Inc.

Summary

The court held that Health and Safety Code section 1430, subdivision (b)'s $500 statutory-damages limit applies once per lawsuit, not separately to each regulatory violation. It relied on the provision's ambiguous text, its relationship to the broader statutory scheme, practical difficulties in counting violations, and legislative history indicating a per-action cap. The court reversed the Court of Appeal's contrary judgment and remanded for further proceedings.