March 26, 2026
Court of Appeal of the State of California, First Appellate District, Division Two
The Rule of Sobalvarro is that a hospital's negligence in failing to offer a disabled female patient the choice of being cared for by a female nurse for intimate care can be a substantial factor causing emotional distress and other harm, under circumstances where the patient is paralyzed, incontinent, requires daily intimate care, and receives such care from a male caregiver contrary to her preferences and the Patient's Bill of Rights.