A Cerritos psychiatric hospital is seeking dismissal of most of the allegations in an alleged “patient dumping” lawsuit brought by a special education teacher with a bipolar disorder who alleges she was discharged in 2017 with little ability to care for herself.

The plaintiff, in her late 30s, is identified only as Jane Doe in the Norwalk Superior Court lawsuit she brought against College Hospital-Cerritos in May 2019. The suit has been twice amended since then.

“By discharging a mentally unstable woman to the street, defendants failed to protect plaintiff from the health and safety hazards to which a psychiatric patient is especially vulnerable upon discharge and abandoned and dumped plaintiff to the streets before her condition had stabilized,” the suit alleges.

But in court papers filed Friday with Judge Olivia Rosales, hospital lawyers dispute Doe’s version of events and are asking the judge to dismiss the plaintiff’s causes of action for dependent adult abuse and neglect, professional negligence, unlawful business practices and intentional infliction of emotional distress, citing both the statute of limitations and the hospital’s legal immunities.

They also say Doe cannot recover punitive damages.

“Plaintiff’s lawsuit reflects her retrospective, if not feigned, dissatisfaction with the determination by a certification hearing officer who protected her constitutional liberty rights, requiring her discharge,” the hospital lawyers said in their court papers.

After being taken by law enforcement to the hospital and being admitted in May 2017, management sought to extend Doe’s 72-hour hold to 14 days, but she objected and wanted to be discharged after a full due process hearing, the hospital lawyers further state in their court papers.

Prior to her release, Doe was instructed regarding her discharge orders and told about available post-discharge care and treatment options, but she declined them all and left “on her own volition,” the hospital attorneys argue in their court papers.

Dr. Manolito Fidel, who was Doe’s treating psychiatrist at the hospital and signed her discharge order, has filed a similar motion, saying he was not added to the case until nearly four years after it was filed and that all the claims against him are barred by the statute of limitations.

According to the suit, Doe has a psychiatric history of manic depression and generalized anxiety since 2008, with recurrent mania psychosis.

In April 2017, Doe, who worked as a special education teacher, went missing from her Canoga Park home, leaving her cellphone, identification and her dog, the suit states.

Doe was arrested shortly thereafter by Huntington Beach police for speeding and evading a peace officer and given a citation, the suit states. She was later released by the HBPD and subsequently was reported missing by hermother, according to the suit.

Doe was found by Fountain Valley police in May 2017 and told them she was homeless, the suit states.   The  Crisis Stabilization Unit of the Orange County Health Care Agency placed Doe at College Hospital-Cerritos, the suit states. While Doe was a patient at College Hospital, the staff failed to obtain an accurate patient history and neglected to provide adequate treatment and post-discharge care, the suit alleges.

Doe’s mother learned of her daughter’s whereabouts and was promised by a staff member that Doe was not to be discharged before she got there, the suit states.

However, as Doe’s mother left the administration building of the hospital with two College Hospital supervisors, she saw her daughter walking through the parking lot by herself leaving the hospital, the suit states.

Doe “began to run and disappeared into the streets of Cerritos,” the suit states.

“Because of College Hospital’s utter neglect, plaintiff’s mother was unable to keep her promise to Plaintiff that she would not let her end up on the streets again,” the suit states. “During the several days plaintiff spent homeless, cold and wandering the streets, she was injured and suffered greatly, including by being sexually assaulted twice,” the suit alleges.

After she was “miraculously” located in Culver City, Doe’s psychiatric state caused her to be placed on another involuntary psychiatric hold, the suit states.

Following months of intensive in-patient treatment, Doe returned home, where her mother served as her fulltime caregiver, living with her daughter for several months and taking care of Doe, her dog, her property and all other decisions concerning her daughter’s affairs, including finding her a new treating physician, according to the suit.

Fidel’s motion is scheduled for hearing April 30, followed by the hospital’s on June 11.