Judge: Alison Mackenzie, Case: 20STCV35154, Date: 2024-04-09 Tentative Ruling



Case Number: 20STCV35154    Hearing Date: April 9, 2024    Dept: 55

NATURE OF PROCEEDINGS: Exchange Building, LP’s Motion for Summary Judgment Or, Alternatively, Summary Adjudication on The Complaint.

 

BACKGROUND

BROADWAY EXCHANGE BUILDING, LP (“Plaintiff”) brings this case against VIANEY SANDERSON (“Defendant”) for Defendant’s alleged breach of her lease with Plaintiff. Plaintiff’s causes of action are (1) Breach of Lease and (2) Breach of Guaranty.

Plaintiff brings a motion requesting summary judgment on its claims, or summary adjudication of the following issues: 1) Defendant Sanderson’s obligation under the parties’ lease agreement to pay rent to Plaintiff between April 2020 and December 2020 was not excused due to the COVID-19 pandemic and resulting government orders; 2) Defendant Sanderson abandoned the Premises on November 25, 2020; and 3) Defendant Sanderson’s fixed-term lease for the premises expired on December 31, 2020. Plaintiff opposes the motion as to each claim and issue raised by the motion.

 

 

LEGAL STANDARD

The initial burden rests with the side moving for summary judgment before the burden to raise triable issues shifts to the opposing party. Scalf v. D. B. Log Homes, Inc. (2005) 128 Cal.App.4th 1510, 1519.

ANALYSIS

1.      Whether The Motion Is Procedurally Defective

Plaintiff contends that the motion fails because the issues stated in the notice do not dispose of any entire cause of action as required.

“[T]he code does not employ the term ‘partial summary judgment,’ presumably because it is a misnomer since no judgment is entered in connection with that procedure of granting summary adjudication of issues.”  City of Santee v. Sup. Ct. (1991) 228 Cal.App.3d 713, 720, fn.5. Legislative intent is that an issue shall be worded to dispose of an entire cause of action or defense. E.g., Nazir v. United Airlines, Inc. (2009) 178 Cal.App.4th 243, 249. A plaintiff cannot obtain summary adjudication as to liability while leaving the amount of damages to be determined later. Paramount Petroleum Corp. v. Sup. Ct. (2014) 227 Cal.App.4th 226, 241.

To be considered, all evidence referenced in a separate statement must be filed and part of the court record. West v. Sundown Little League of Stockton, Inc. (2002) 96 Cal. App. 4th 351, 363. 

Here, Plaintiff did not word the notice’s issues to dispose of any entire claim or defense. Further, the notice and separate statement do not state any complete amount of damages to dispose of the claims. Likewise, the reply uncertainly argues for an unspecified amount of damages in addition to other types. E.g., reply, 3:19-22 (“damages in the amount of $54,450.00 for rent due and unpaid under the Lease for the months of April 2020 through December 2020…, and such other relief as may be just.”). Because the Complaint and other documents seek unlimited damages, factfinders would need to decide the dispute about abandonment and the length of the lease, before deciding any other damages that may be available. See Avalon Pac.-Santa Ana, L.P. v. HD Supply Repair & Remodel, LLC (2011) 192 Cal. App. 4th 1183, 1211; and Civ. Code § 1951.2.

Therefore, on procedural grounds, the law does not authorize the Court to grant summary judgment without resolving damages, or summary adjudication of the issues addressing only parts of the claims of defenses. Nevertheless, the Court will proceed to address the merits.

2.      Whether Defendant’s Obligation to Pay Rent Between April 2020 and November 2020 was Excused Due to the COVID-19 Pandemic and Resulting Government Orders

Plaintiff alleges claims against Defendant for breach of lease and breach of guaranty. The elements of a claim for breach of lease are:

  1. Existence of contract or lease;
  2. plaintiffs’ performance or excuse for nonperformance;
  3. defendants’ breach; and
  4. resulting damage.

Wall Street Network, Ltd. v. N. Y. Times Co. (2008) 164 Cal.App.4th 1171, 1178

The elements of a claim for breach of guaranty are:

1.                  Defendant guaranteed payment of the indebtedness of the primary obligor to the plaintiff;

2.                  default on the indebtedness;

3.                  plaintiff notified the guarantor of the default;

4.                  the guarantor did not remit funds to the plaintiff under the guaranty agreements. 

Torrey Pines Bank v. Sup. Ct. (1989) 216 Cal.App.3d 813, 819. 

Plaintiff contends that the pandemic lockdown did not frustrate the purpose of the subject lease or excuse the failure to pay rent owed.  Defendant counters based on her declaration describing the pandemic as causing lost business revenue, and thus an inability and temporary excuse.

A commercial lessee’s force majeure provision does not excuse paying rent, unless the capability was delayed, interrupted, or prevented by COVID-19, due to timely performance being impossible or impracticable with extreme and unreasonable difficulty. KB Salt Lake III, LLC v. Fitness Int'l, LLC (2023) 95 Cal.App.5th 1032, 1054 (“There is no triable issue of fact … because [the tenant] admitted that it had the financial resources to pay rent ... for the subject months, even though ... operating at a loss.”). Commercial tenants remain obligated to pay rent pursuant to the lease while in possession of the premises. E.g., SVAP III Poway Crossings, LLC v. Fitness Int'l, LLC (2023) 287 Cal.App.5th 882, 896. “The Moratorium also provided tenants with a year-long forbearance period after the Moratorium ends to pay overdue rent.” Iten v. Los Angeles (9th Cir. 2023) 81 F.4th 979, 982. The moratorium has been applied to commercial tenants having nine or fewer employees. See Los Angeles County COVID-19 Eviction Moratorium (Exec. Order of the Chair of the Los Angeles County Board of Supervisors, § III(e) (9/1/20)). So, although Defendant’s obligation to pay rent was not excused, it was legitimately delayed.

Applying the applicable law, the Court determines that Plaintiff adequately evidenced that Defendant has failed to pay rent even after the expiration of the moratorium. However, Defendant’s declaration, at paragraphs 4 through 5, raises disputes about a pandemic-related excuse for the lessee’s at least temporarily failing to pay rent.

Thus, this issue is denied, in relation to the dispute about a temporary excuse of the obligation to pay some rent.

 

3.      Whether Defendant Abandoned the Premises on 11/25/20  

The Court determines that Plaintiff shifted the burden of proof to show tenant abandonment, including based on evidence that Plaintiff permanently vacated the subject property, and that Defendant did not enter it until after the lease term expired. In opposition, Defendant contends that her deposition testimony did not state any intent to go out of business, but instead to close a few weeks to hire new staff. Further, Defendant’s declaration and exhibits reasonably infer that Plaintiff intended to stay as an occupant of the subject premises, given ongoing communications with the Defendant.

Under the disputed circumstances in evidence, factfinders reasonably could find that Plaintiff did not believe that Defendant vacated the premises, when Defendant left personal property on the premises worth approximately $150,000, Defendant and the Plaintiff continuingly discussed plans to reopen the business, and Defendant continued to pay utility bills. (E.g., Sanderson decl., ¶¶ 6-16.)

Therefore, the motion is denied as to this issue, given disputes about whether tenant abandonment occurred.

 

4.      Whether Plaintiff’s Fixed-Term Lease for the Premises Expired on 12/31/20 Such That Entry Afterwards Was Not Wrongful.

Regarding the initial burden, Plaintiff provides evidence that Defendant never exercised the option to extend the lease, such that Plaintiff permanently vacated the subject property, and Defendant did not enter the property until after the lease term expired. (Boris Mayzels Decl., ¶¶ 3 and 14.) In contrast, Plaintiff’s declaration shows exercising the option to extend the lease. (Sanderson Decl., ¶ 3.)

Hence, the motion is denied as to this issue that is related to disputed evidence about the lease term.

 

CONCLUSION

The Court denies the motion for summary judgment, and alternative motion for summary adjudication.