# Opposition Brief — Easton v. Maready

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URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386010_1250%3A2

## Record

- **Collection:** Supreme Court brief
- **Document type:** Opposition Brief
- **Published:** January 1, 2002
- **Citation:** 537 U.S. 818

## Text

No. 01-1735 JUN oe 2000

ae ne ie meer eee

IN THE

Supreme Court of the United States ~~~

|
j

TOM EASTON and ELENA EASTON,
and as successors in interest of decedent
MARGARETHA MARY WINCHESTER,

Petitioners,
v.

JIM MAREADY, DEL NORTE SHERIFF;
DEPUTY SHERIFF THOMAS HOCKABOUT;
DEPUTY SHERIFF GERALD HARWOOD;
DEPUTY SHERIFF GARTH GOODRICH;
STEPHAN BROHMER, DIRECTOR DEL NORTE ADULT
PROTECTIVE SERVICES; and DOES ONE through TEN,
inclusive, each in their individual and official capacity,

Respondents.

On PETITION FOR A WRIT OF CERTIORARI TO THE
Court OF APPEAL OF THE STATE OF CALIFORNIA

BRIEF IN OPPOSITION

JOHN M. VRIEZE
Counsel of Record
WILLIAM F. MITCHELL
MITCHELL, Brisso,
DELANEY & VRIEZE
Attorneys for Respondents
814 Seventh Street
P.O. Drawer 1008
Eureka, CA 95502
(707) 443-5643

174680 cel

COUNSEL PRESS
(800) 274-3321 + (800) 359-6859

i

TABLE OF CONTENTS

Page
Table of Cited Authorities ..................... il
I i ds dd ee a a O% Oe Oe l
Reasons for Denying the Writ.................. 4
A. The Issues Presented To This Court Were Not
I a ys 4
B. The California Elder Abuse Act and the
Decision Below are Consistent with the
Fourth Amendment. ............0cccc0e- 8
C. The California Elder Abuse Act is Consistent
with 42 U.S.C. § 1395Scc. . cee e ee eeseeess iZ

CNR RRR REN a re EN ean LE NR a Re 13

il

TABLE OF CITED AUTHORITIES

Cases: act
Campbell v. Louisiana, 423 U.S. 392 (1998) ..... 5,7
Cardinale v. Louisiana, 394 U.S. 437 (1969) ..... 5,6
Crowell v. Randell, 10 Pet. 368 (1836) .......... 5
Delaney v. Baker, 20 Cal. 4th 23 (1999) ......... 8

Easton v. Sutter Coast Hospital, 80 Cal. App. 4th
485 (2000), cert. denied, 531 U.S. 1084,

148 L. Ed. 2d 686, 121 S. Ct. 790 (2001) ..... 3, 9, 12

_ Fuller v. Oregon, 417 U.S. 40 (1974) ........... 7
Illinois v. Gates, 462 U.S. 213 (1983) ........... 5
Johnson v. State, 386 So. 2d 302 (Fla. App. 1980) ... 11
Johnson y. United States, 333 U.S. 10 (1948) ..... 10
Mann vy. Cannon, 731 F.2d 54 (1st Cir. 1984) ..... 11
Michigan y. Tyler, 436 U.S. 499 (1978) .......... 10
Mincey v. Arizona, 437 U.S. 385 (1978) ......... 10
People v. Ray, 21 Cal. 4th 464 (1999) ........... 11

State v. Butler, 676 S.W.2d 890 (Mo. 1984) ...... 11

iil

Cited Authorities
Page
State v. Carlson, 548 N.W.2d 138 (Iowa 1996) .... 11
State v. Mackins, 47 N.C. App. 168, 266 S.E.2d 694
ES ees ee ery Pe ee reer 11
State v. Max, 263 N.W.2d 685 (S.D. 1978) ....... 11
Street v. New York, 394 U.S. 476 (1969) ......... 7
United States v. Barone, 330 F.2d 543 (2d Cir.
ear oo va hea eae anes 11
United States v. Brand, 556 F.2d 1312 (Sth Cir. —
ee nd <a haa bie ak ooo ok oe 11
United States v. Echegoyen, 799 F.2d 1271 (1986) ... 11
United States v. Gillenwaters, 890 F.2d 679 (4th Cir.
EN es Daas ok s Ub 60668 ba e4Ae ON Oe 11
United States v. Green, 474 F.2d 1385 (5th Cir
a eniiia ss Satoh tee cac ele oe Reb awees 11
United States v. Hogue, 283 F. Supp. 846 (N.D. Ga
Ce ee aL es ieee cee bok 11
United States v. Hughes, 993 F.2d 1313 (7th Cir
SE CR seUely ceed shee bee Ki ke ee ke Oe a 11

United States v. Jones, 635 F.2d 1357 (8th Cir.
EE tiene tice kkvewaeeks SRE Up ar nas, eanae eee 11

iv

Cited Authorities
Page
United States v. Martin, 781 F.2d 671 (9th Cir.

DT Gok once we hand eRe A GaSe ek A 11
United States v. Reid, 69 F.3d 1109 (11th Cir. 1995)

Si ahaa eaten Chek baad KDE enews 10
United States v. Riccio, 726 F.2d 638 (10th Cir.

DE 2 ndknaw adh eee aden en Caner es 11
United States v. Robertson, 606 F.2d 853 (9th Cir.

SEE coh vkcewehen sad vaba chee eee kako 6 10
United States v. Searle, 974 F. Supp. 1433 (M.D. Fla.

ONIN «0.3 as ed ars esta he a a Sc Aaa oe 11
Whitney v. California, 274 U.S. 357 (1927) ...... 5
United States Constitution:

Fourth Amendment ................... 2, 4, 8, 10, 12
Statutes:

Be Chas OE oo bs Cod Fu Kenn e was eee eee 5
ie Ses dan e-kue ne Cees nne eedeacewe 13
ih tom Be as GF) rere 4

MUSE AO Be oe ees 2,4

Vv

Cited Authorities
Page

California Welfare and Institutions Code § 15600 ... 8
California Welfare and Institutions Code § 1561 0.07

ous ola ek he ed eae ae eee ee 9
California Welfare and Institutions Code § 15610.30

ls ae eed beak ee ae ee ene 9
California Welfare and Institutions Code § 15610.43

Prerrrr rer re. OPT ror TT rr errr rT 9
California Welfare and Institutions Code § 15610.57

Pe PP errr eer tr rr se 9
California Welfare and Institutions Code § 15610.63

= be ee feo nek eee ee ee 9
California Welfare and Institutions Code § 15634 ... 3,9
California Welfare and Institutions Code § 15634(b)

a gdueewebebesats een hieueeaegen 9,10, 12
Rule:
United States Supreme Court Rule 14 .......----: 6, 7
Other Authority:

Journal of Criminal Law and Criminology,
Winter 1999 2... ccc cc cccnccecnccccecesoes 11

l

STATEMENT OF THE CASE

Margaretha Winchester resided at her home in Crescent City
with her son, plaintiff Tom Easton (Easton), and Mr. Easton’s
wife, Elena Easton. She had suffered from dementia since 1998.
On September 26, 1998, the 88-year-old Winchester collapsed
outside the residence after returning home from a walk.

Winchester’s physical and mental condition declined
rapidly after this incident, and she was treated at a local
hospital on October 13. She was prescribed medication for a
urinary tract infection and discharged.

Once home, a home healthcare worker (Don Morneau)
monitored her condition, with Easton’s consent. On October
19, the home healthcare worker discovered that Easton had
not filled the prescription to treat his mother’s infection.
The next day, Morneau strongly urged Easton to take Winchester
back to the hospital for treatment of the infection, an easily
treatable medical condition. Easton refused and indicated he
did not want to have medical personnel attend to her. At this
time, Easton did not have a power of attorney to make health
care decisions for Winchester and he had not been appointed
her guardian. Morneau then told Easton it was his duty to
report possible elder abuse.

Morneau then reported the refusal to allow medical
care to Winchester’s treating physician (Dr. Sara Kossuth).
Dr. Kossuth then called 911 and reported that Easton would
not allow medical personnel to treat Winchester’s infection,
also suggesting that his neglect constituted elder abuse.
The physician also reported that Winchester’s infection
posed a risk of falling blood pressure, which could be

2

life-threatening, and requested that law enforcement personnel
intervene and assist in having Winchester brought to the
hospital.’

Three Del Norte County sheriff’s deputies were dispatched
to the Easton residence in response to the physician’s request.
A deputy (Deputy Hockabout) informed Easton that they had
been dispatched to assist in having Winchester taken to the
hospital for necessary medical care. Hockabout then entered
the house, followed by an emergency medical technician (EMT)
from Del Norte Ambulance. The EMT reported that
Winchester’s blood pressure was very low. Deputy Hockabout
observed that Winchester appeared in very poor health. She was
completely unresponsive to his questions. At all times her eyes
were open. She stared directly at him without any response.
Deputy Hockabout then concluded that Winchester was severely
disabled — both mentally and physically. She appeared
malnourished, weak and frail. Deputy Hockabout determined
that Winchester was unable to understand the risks to her health,
and allowed medical personnel to transport her to the hospital
~ by ambulance. ;

Petitioners filed suit in the Del Norte County Superior
Court, alleging violation of 42 U.S.C. § 1983 based on the
Eastons’ Fourth Amendment rights. The complaint also alleged
that the County violated California’s Elder Abuse Act by failing
to obtain a search warrant before entering the Easton’s home.

1. In a memo of a prior conference call between Morneau,
Dr. Kossuth and Chris Van Camp, a social service worker, it is noted,
“Dr. Kossuth wants patient in ER for assessment ‘whatever it takes.””

Fh tte

“3

The state trial court granted respondents’ motion for
summary judgment and petitioners appealed. In an unpublished
opinion? (“Easton IT’’), the California Court of Appeal affirmed
the trial court’s granting of summary judgment, based on an
immunity provision in the Elder Abuse Act, previously addressed
by the court in Easton v. Sutter Coast Hospital, 80 Cal. App.
4th 485 (2000), cert. denied, 531 U.S. 1084, 148 L. Ed. 2d
686, 121 S. Ct. 790 (2001) (“Easton I’’). Both Easton I and
Easton II are based on the same underlying incident, i.e.,
the removal of Winchester from the Easton residence in order
to render medical treatment.

In Easton I, the appellate court construed California Welfare
and Institutions Code § 15634 (a provision of the Elder Abuse
Act) toconfer absolute immunity for persons who provide access
to victims of suspected abuse. /d., 80 Cal. App. 4th at 495-496.
Under the facts presented in this case, the court in Easton II
concluded that the same statute “provides absolute immunity
to the sheriff’s deputies who entered the home without a
warrant in order to allow [ ] paramedics to remove Winchester.”
Easton IT, 2001 WL 1511263 (Cal. App. 1 Dist.), *3.

Petitioners then filed a petition for review with the
California Supreme Court, which was denied.

2. Acopy of the decision is attached as an appendix to the petition
for writ of certiorari, and is available on Westlaw (2001 WL 1511263).

4
REASONS FOR DENYING THE WRIT

A. The Issues Presented To This Court Were Not Raised
Below.

Petitioners present two issues. First, they claim California’s
Elder Abuse Act is facially unconstitutional under the Fourth
Amendment of the United States Constitution. Second,
petitioners (apparently) assert that this legislation conflicts
with 42 U.S.C. § 1395cc(f)(1)(A)(i), a provision of the Patient
Self Determination Act.’

Neither of these issues were raised or addressed in the
proceeding below.

The complaint alleged respondents violated § 1983 and the
Elder Abuse Act, based on the entry into petitioners’ residence
without a search warrant. Petitioners did not challenge the
constitutionality of the Elder Abuse Act, nor did they allege
that the Act conflicted with the so-called Patient Self
Determination Act.

Likewise, petitioners did not question the validity of the
Elder Abuse Act in their brief filed in the California Court of
Appeal or their petition for review to the California Supreme
Court. To the contrary, they argued that “California law is in
accord with federal law” with respect to the right of patients to
refuse medical treatment.‘

3. The second issue is articulated by petitioners as follows:
“May California’s Elder Abuse Act legislate away an elder patient’s
right to refuse unwanted medical treatment under the Patient Self
Determination Act, 42 U.S.C. § 1395cc(f)(1)(A)(@) without violating
her civil rights under 42 U.S.C. § 1983?”

4. Petitioners’ opening brief, filed in the California Court of
Appeal, pp. 38-39.

5

The failure of petitioners to raise either of the issues in
the proceedings below is reflected in the Court of Appeal’s
decision in Easton II. That is, a constitutional challenge to
California’s Elder Abuse Act under federal law was not
addressed in that decision, nor does the court indicate that
the issue was raised by petitioners. Rather, the issue before
the appellate court was whether or not California’s Elder
Abuse Act provided immunity for respondents.°

Petitioners ignore the well-established rule that, on
petition for certiorari from state court decisions, this Court
does not decide federal issues “not pressed or passed upon
below.” Campbell v. Louisiana, 423 U.S. 392, 401 (1998);
Illinois v. Gates, 462 U.S. 213, 218-220 (1983); Cardinale
v. Louisiana, 394 U.S. 437, 439 (1969); Crowell v. Randell,
10 Pet. 368, 391-398 (1836). Indeed, the Court has opined
that, under 28 U.S.C. § 1257,° it lacks jurisdiction to even
consider federal questions not raised or decided by the highest
state court below. Crowell, 10 Pet. at 391; Whitney v.
California, 274 U.S. 357, 360 (1927); Cardinale, 39 U.S. at
438 (“It was very early established that the Court will not
decide federal constitutional issues raised here for the first
time on review of State court decisions.”).

5. The appellate decision also mentioned, in passing, petitioners’
claim that the trial court violated their constitutional right to a jury
trial by granting summary judgment 2001 WL 1511263*4.

6. Section 1257 provides that:

[FJinal judgments or decrees rendered by the highest
court of a State in which a decision could be had, may be
reviewed by the Supreme Court as follows: ... (3) by
writ of certiorari, . .. where any title, right, privilege or
immunity is specially set-up or claimed under the
Constitution, treaties or statutes of. . . the United States.

6

The policies giving rise to the so-called “not pressed or
passed upon below” rule were explained by the Court in
Cardinale v. Louisiana, supra:

In addition to the question of jurisdiction arising
under the statute controlling our power to review
final judgments of state courts, 28 U.S.C. § 1257,
there are sound reasons for this. Questions not raised
below are those on which the record is very likely to
be inadequate, since it certainly was not compiled
with those questions in mind. And in a federal system
it is important that state courts be given the first
opportunity to consider the applicability of state
statutes in light of constitutional challenge, since the
statutes may be construed in a way which saves their
constitutionally. Or the issue may be blocked by an
adequate state ground. Even though States are not
free to avoid constitutional issues on inadequate state
grounds. [citation omitted] They should be given the
first opportunity to consider them.’

Supreme Court Rule 14 requires that a petition for
review of a state court judgment include a statement
specifying

... the stage and the proceedings, both in the court
of first instance and in the appellate courts, when
the federal question sought to be reviewed were
raised; the method or manner of raising them and
the way in which they were passed on by those
courts; and pertinent quotations of specific
portions of the record or summary thereof, with

7. 394 US. at 439.

7

specific references to the places in the record
where the matter appears ... so as to show that
the federal question was timely and properly raised
and that this Court has jurisdiction to review the
judgment on a writ of certiorari.

Consistent with Supreme Court Rule 14, courts have held
that the petitioner has the burden of demonstrating to this
Court that the federal questions were raised or decided by
the state court below. Street v. New York, 394 U.S. 476, 482
(1969); Campbell, 523 U.S. at 401; Fuller v. Oregon, 417
U.S. 40, 50 n.11 (1974). This Court has also stated that, when
“the highest court has failed to pass upon a federal question,
it will be assumed that the omission was due to want of proper
presentation in the state courts, unless the aggrieved party in
this Court can affirmatively show the contrary.” Street, 394
U.S. at 582 (emphasis added).

Petitioners have utterly failed to carry their burden to
provide a record to this Court showing that the validity of
California’s Elder Abuse Act was challenged on federal
constitutional or federal statutory grounds in the proceedings
below. Indeed, as discussed above, no such showing can be
made, as the federal questions are now raised for the first time.

Accordingly, the petition for a writ of certiorari must be
denied. |

B. The California Elder Abuse Act and the Decision
Below are Consistent with the Fourth Amendment.

Even assuming arguendo that the federal issues presented
here were raised or decided below, review by this Court would

8

not be warranted.

California’s Elder Abuse Act, as amended in 1991, is
designed to protect the elderly and dependant persons from
abuse, neglect, or abandonment. Delaney v. Baker, 20 Cal.
4th 23, 42 (1999), citing California Welfare and Institutions

Code § 15600.*

8. Section 15600, which sets forth the legislative declarations

and intent of the Elder Abuse Act provides, inter alia:

The Legislature recognizes that elders and dependent
adults may be subjected to abuse, neglect, or
abandonment and that this state has a responsibility to
protect these persons ... The Legislature further
recognizes that a significant number of these persons
have developmental disabilities and that mental and
verbal limitations often leave them vulnerable to abuse
and incapable of asking for help and protection ...
The Legislature recognizes that most elders and
dependent adults who are at the greatest risk of abuse,
neglect, or abandonment by their families or caretakers
suffer physical impairments and other poor health that
place them in a dependent and vulnerable position .. .
The Legislature declares that this state shall foster and
promote community services for the economic, social,
and personal well-being of its citizens in order to
protect those persons described in this section ...
The Legislature further declares that uniform state
guidelines, which specify when county adult protective

(Cont’d)

9

The Act provides that any local law enforcement agency
employee who provides an agency reporting suspected elder
abuse’ with access to the victim of a known or suspected
instance of elder or dependant adult abuse shall not incur
civil or criminal liability as a result of providing that access.
§ 15634(b). In Easton I, the State appellate court determined
that the immunity set forth in § 15634, provided absolute
immunity from claims of trespass and false imprisonment made
by the petitioners against medical personnel. 80 Cal. App. 4th
at 495-496. In Easton II, the court found, under the facts in
this case, that this immunity protection extended to the
respondent law enforcement officers, who entered without a

(Cont’d)
service agencies are to investigate allegations of abuse
of elders and dependent adults and the appropriate role
of local law enforcement is necessary in order to ensure
that a minimum level of protection is provided to elders
and dependent adults in each county . . . Therefore, it is
the intent of the Legislature in enacting this chapter to
provide that adult protective services agencies, local
long-term care ombudsman programs, and local law
enforcement agencies shall receive referrals or
complaints from public or private agencies, from any
mandated reporter submitting reports pursuant to Section
15630, or from any other source having reasonable cause
to know that the welfare of an elder or dependent adult
is endangered, and shall take any actions considered
necessary to protect the elder or dependent adult and
correct the situation and ensure the individual’s safety.

9. Elder abuse can arise a number of ways — physical abuse,
neglect, abandonment, isolation, financial abuse, deprivation by a
care custodian of necessary goods or services, or other treatment
that results in physical harm, pain, or mental suffering. (Welfare and
Institutions Code §§ 15610.07, 15610.30, 15610.43, 15610.57, and
15610.63.)

10

warrant in order to allow medical personnel to remove
Winchester.

Petitioners argue that the immunity set forth in § 15634(b)
— as written and as applied by the court in Easton I] —
“unconstitutionally deprives elder citizens of their right under
the Fourth Amendment to be safe and secure in their own
homes.” Plaintiffs further assert that the appellate court’s
interpretation of § 15634(b) “appears an absurd reading in light
of Fourth Amendment jurisprudence.”

Contrary to petitioners’ argument, courts have consistently
held that warrantless entry into a home does not violate the
Fourth Amendment, where the entry is made necessary by
exigent circumstances. Michigan v. Tyler, 436 U.S. 499, 509
(1978); United States v. Robertson, 606 F.2d 853, 859 (9th Cir.
1979); Johnson v. United States, 333 U.S. 10, 14-15 (1948);
United States v. Reid, 69 F.3d 1109, 1113-1114 (11th Cir. 1995).

In Mincey v. Arizona, 437 U.S. 385, 392 (1978) this Court
recognized that the most urgent emergency situation excusing
police compliance with the warrant requirement is the need to
protect or preserve life:

Numerous state and federal cases have recognized
that the Fourth Amendment does not bar police
officers from making warrantless entries and
searches when they reasonably believe that
a person within is in need of immediate aid ...
The need to protect and preserve life or avoid serious
injury is justification for what would be otherwise
illegal absent and exigency or emergency.

Following Mincey v. Arizona, both federal and state courts
have consistently upheld warrantless emergency entries and

—_—_-s

ENS me ERIM 5 Baha Pde tg

11

searches based on endangerment to life. See, e.g., People v.
Ray, 21 Cal. 4th 464, 470 (1999) (no warrant required when
law enforcement rendering “emergency aid”); United States
v. Echegoyen, 799 F.2d 1271 (1986) (/d.); United States v.
Hughes, 993 F.2d 1313 (7th Cir. 1993) (report of woman
and child in danger in crack house); United States v.
Gillenwaters, 890 F.2d 679 (4th Cir. 1989) (stabbing victim);
United States v. Martin, 781 F.2d 671 (9th Cir. 1985)
(explosion in apartment); Mann v. Cannon, 731 F.2d 54 (lst
Cir. 1984) (open access to controlled substances by children);
United States v. Riccio, 726 F.2d 638 (10th Cir. 1984)
(medical aid to defendant shot by police); United States v.
Jones, 635 F.2d 1357 (8th Cir. 1980) (report of gunshots);
United States v. Barone, 330 F.2d 543 (2d Cir. 1964) (screams
in the night); United States v. Searle, 974 F. Supp. 1433 (M.D.
Fla. 1975) (report of gunshots); United States v. Hogue, 283
F. Supp. 846 (N.D. Ga. 1968) (report of dead body); Johnson
v. State, 386 So. 2d 302 (Fla. App. 1980) (report of dead
body); State v. Carlson, 548 N.W.2d 138 (Iowa 1996)
(missing person); State v. Butler, 676 S.W.2d 890 (Mo. 1984)
(en banc) (gunshot victim); State v. Mackins, 47 N.C. App.
168, 266 S.E.2d 694 (1980) (gunshots); State v. Max, 263
N.W.2d 685 (S.D. 1978) (gunshots). United States v. Brand,
556 F.2d 1312 (5th Cir. 1977) (noting defendant’s concession
that police officer who assisted ambulance attendants with
medical emergency legally entered home); United States v.
Green, 474 F.2d 1385 (5th Cir. 1973) (indicating deputy fire
marshal could validly search apartment to determine cause
of fire where ascertaining cause was necessary to assure fire
was completely extinguished); See generally, “Emergency
Circumstances, Police Responses, And Fourth Amendment
Restrictions,” Journal of Criminal Law and Criminology,
Winter 1999 pp. 439-441 (collecting cases involving
warrantless entry when person in need of medical treatment).

12

In short, providing immunity to law enforcement officers
entering a home without a warrant in order to assist medical
personnel rendering assistance to the victim of a known
or suspected instance of elder or dependant adult abuse
under § 15634(b) is completely consistent with recognized
exceptions to the Fourth Amendment warrant requirement
established by this and other courts.

Furthermore, the undisputed facts in this case establish that
Deputy Hockabout reasonably believed Winchester was in
immediate need of medical attention. Therefore, exigent
circumstances existed, obviating the need for a warrant.

C. The California Elder Abuse Act is Consistent with
42 U.S.C. § 1395ce.

Petitioners’ claim that the Elder Abuse Act is somehow
inconsistent with the so-called Patient Self Determination Act
warrants little discussion.

As discussed above, this issue was neither raised nor
decided in the state court proceedings.

In any case, at no time did Deputy Hockabout see
Winchester, who had suffered from dementia for many years,
act in any fashion to suggest that she was knowingly denying
consent. Furthermore, none of the Del Norte County Sheriff’s
deputies rendered medical treatment, and at no time while
hospitalized did Winchester refuse medical care provided.'®

10. There is no evidence that, after arriving at the hospital, .
Winchester declined medical care or otherwise objected to treatment
modalities. (See also, Easton I, 80 Cal. App. 4th at 323, under the
facts alleged in the complaint the California Court of Appeals in
Easton I assumed “Winchester was competent to decline to be
admitted to the hospital.”)

13

As petitioners acknowledge at page 6 in their petition for a
writ of certiorari, the Elder Abuse Act allows any victim of elder
or dependent adult abuse to refuse consent. Hence, there is no
conflict between the California Elder Abuse Act and 42 U.S.A.
§ 1395cc. Because there is no conflict between the Elder Abuse _
Act and the identified federal statute, certiorari must also be
denied as to the second issue presented.

CONCLUSION

For all the above stated reasons, the petition for a writ
of certiorari should be denied.

Respectfully submitted,

JOHN M. VRIEZE

Counsel of Record
WILLIAM F. MITCHELL
MITCHELL, BrRIsso,
DELANEY & VRIEZE
Attorneys for Respondents
814 Seventh Street

P.O. Drawer 1008
Eureka, CA 95502
(707) 443-5643

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386010_1250%3A2. Public record. Not legal advice.