What is the meaning of the reasonable licensee defense under section 1424 of the Health and Social Care Licensing Act?

In order to interpret the meaning of the reasonable licensee defense, we must first understand the nature of the statutory scheme of which that defense is part. As discussed, section 1424 is one section of the Act. The declared legislative intent of the Act is to "establish (1) a citation system for imposition of prompt and effective civil sanctions against long-term health care facilities in violation of the laws and regulations of this state ... relating to patient care; (2) an inspection and reporting system to ensure that long-term health care facilities are in compliance with state statutes and regulations pertaining to patient care; and (3) a provisional licensing mechanism to ensure that full-term licenses are issued only to those long-term health care facilities that meet state standards relating to patient care." ( 1417.1.) The Act covers skilled nursing facilities as well as intermediate care facilities of various types. ( 1418.)

We summarized the licensing enforcement regime under the Act in Kizer v. County of

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