Judge: Alison Mackenzie, Case: 21STCV39486, Date: 2024-04-29 Tentative Ruling



Case Number: 21STCV39486    Hearing Date: April 29, 2024    Dept: 55

NATURE OF PROCEEDINGS: Motion Of Plaintiff/Cross-Defendant Tony Lewis For Summary Judgment, Or In The Alternative, Summary Adjudication.

BACKGROUND

TONY LEWIS (“Plaintiff”) filed suit against JASON E. UPCHURCH as personal representative of the Estate of DARLENE J. UPCHURCH-FRIEDMAN (“Upchurch”), and  JEFFERSON LA BREA D&J PROPERTIES, LLC (“Jefferson”) (Upchurch and Jefferson collectively referred to herein as “Defendants”) alleging, among other claims, a claim for declaratory relief in connection with a Partnership Agreement and Operating Agreement purportedly entered into between Plaintiff and Darlene J. Upchurch-Friedman for properties located on La Brea Avenue and W. Jefferson Boulevard in Los Angeles (the “Property”).

Defendants’ Cross-Complaint alleges claims against Plaintiff for trespass, intentional interference with prospective economic relations, breach of fiduciary duty, and declaratory judgment. In addition, Jefferson alleges a claim for intentional interference with contractual relations and Upchurch alleges a claim for elder abuse.

Jefferson is in bankruptcy and thus subject to a bankruptcy stay. But Upchurch is not in bankruptcy. Now, Plaintiff brings a motion for summary adjudication that Upchurch has no defense to Plaintiff’s claim for declaratory relief. Plaintiff also seeks summary judgment or, alternatively, summary adjudication that all of Upchurch’s claims in the Cross-Complaint lack merit. Upchurch opposes the motion.  

EVIDENTIARY RULINGS/REQUESTS FOR JUDICIAL NOTICE

The Court sustains Upchurch’s objection number 23 and overrules the other objections. The Court grants the unopposed requests for judicial notice filed by Plaintiff and Upchurch.

LEGAL STANDARD

In moving for summary judgment or summary adjudication, a “plaintiff . . . has met his or her burden of showing that there is no defense to a cause of action if that party has proved each element of the cause of action.”  Code Civ. Proc., § 437c(p)(1). The burden then shifts to the plaintiff to show that a triable issue of one or more material facts exists as to the cause of action or a defense thereto. Code Civ. Proc., § 437c(p)(1).

For summary judgment or adjudication brought by a cross-defendant, the moving party has the initial burden of showing a cause of action has no merit “if the party has shown that one or more elements of the cause of action … cannot be established, or that there is a complete defense to the cause of action.” Code Civ. Proc., § 437c(p)(2). A party moving for summary adjudication of an affirmative defense has the initial burden to make a prima facie showing that that the affirmative defense is without merit. Continental Ins. Co. v. Columbus Line, Inc. (2003) 107 Cal.App.4th 1190, 1199-1200. “[T]he defendant must make an affirmative showing that the plaintiff will be unable to prove its case by any means.” Weber v. John Crane, Inc. (2006) 143 Cal.App.4th 1433, 1439. “Summary judgment is proper only where there are no triable issues of material fact and the moving party is entitled to judgment in its favor as a matter of law.” Assad v. Southern Pacific Transportation Co. (1996) 42 Cal.App.4th 1609, 1612.

ANALYSIS

1.      Complaint’s Claim for Declaratory Relief and Cross-Complaint’s Sixth Cause of Action for Declaratory Judgment

Plaintiff’s declaratory relief claim seeks a declaration that, inter alia, Plaintiff is a member and manager of Jefferson pursuant to the Partnership Agreement and Operating Agreement. Similarly, Upchurch’s claim for declaratory judgment seeks a declaration that the estate of Ms. Upchurch-Friedman is the sole member of Jefferson.

Plaintiff contends that Upchurch has no defense to Plaintiff’s claim and cannot establish his own claim for declaratory judgement because the undisputed facts establish that Plaintiff is a member and manager of Jefferson and he never sold his interest in Jefferson and/or any such sale was rescinded by the parties.  

The elements of a claim for declaratory relief are: 1) person seeks a declaration of his or her rights or duties with respect to another or in respect to property; and 2) an actual controversy. Ludgate Ins. Co. v. Lockheed Martin Corp. (2000) 82 Cal.App 4th 592, 605-606.

Plaintiff sets forth facts in his declaration to support his claim and dispute Upchurch’s claim and therefore shifts the burden to Upchurch. But the Court concludes, like the motion decided 4/25/23, that triable issues of fact exist as to whether the 2014 Membership Purchase Agreement was or was not a sham. Def’s Response to Pl’s UMF Nos. 7-8, 10-11, 13-16, 153-154, 156-157, 159-162. This includes triable issues of fact as to whether Ms. Upchurch-Friedman took steps after Plaintiff’s alleged repurchase of his interests in Jefferson consistent with Plaintiff’s version of events. Id., Nos. 17, 19-27, 163-173. For instance, Plaintiff testified to taking steps to legitimately repurchase a 30 percent membership interest, but he lacks a written, executed modification required by agreement. Russell Glazer Decl., Ex. 1 (Plaintiff’s depo.), pp. 246, 262-264. See Dart Indus., Inc. v. Com. Union Ins. Co. (2002) 28 Cal.4th 1059, 1068 (written contract terms may be proved by oral evidence, if the proponent lacks possession or control of a writing not reasonably procurable, subject to any disputes over terms or injustice and unfairness).

Thus, the Court denies the motion as to the parties’ respective claims for declaratory relief.

2.      Cross-Complaint’s First Cause of Action for Trespass

Plaintiff argues that the trespass claim in the Cross-Complaint fails because he has been and is a member and manager of Jefferson and therefore has had the right to enter the Property.

The elements of a claim for trespass are: 1) Plaintiff's ownership, or control, of the property; 2) defendant's intentional, reckless, or negligent, entry onto property; 3) lack of permission for entry, or actions in excess of permission; 4) harm; and 5) the actions were a substantial factor in causing harm. Ralphs Grocery Co. v. Victory Consultants, Inc. (2017) 17 Cal.App.5th 245, 262.

As analyzed with respect to the first issue, there are disputes about whether Plaintiff remained a member and manager of Jefferson having control over and permission to enter the property.

Thus, the Court denies the motion as to this issue.

3.      Cross-Complaint’s Second Cause of Action for Intentional Interference with Contractual Relations and Third Cause of Action for Intentional Interference with Prospective Economic Relations

Plaintiff argues that he has been and is a member and manager of Jefferson and therefore did not wrongfully interfere with any contractual or economic relations. Plaintiff’s arguments about standing with respect to the second cause of action for intentional interference with contractual relations is inapposite because the Cross-Complaint makes clear that only Jefferson (not Upchurch) asserts that claim against Plaintiff.

As for the Third Cause of Action, Upchurch sues as personal representative of the Estate of Darlene J Upchurch-Friedman regarding the decedent’s property interests. See Cross-Complaint, ¶¶ 4-6. Thus, injury to the individual cross-complainant is not an issue framed by the pleading. Instead, injury to the decedent is the issue alleged. “Generally, an executor or other personal representative is the person authorized to maintain or defend an action on behalf of a probate estate.” Ring v. Harmon (2021) 72 Cal.App.5th 844, 850. Parties moving for summary judgment cannot base the motion upon theories not pled. ….”  Nieto v. Blue Shield of Cal. Life & Health Ins. Co. (2010) 181 Cal.App.4th 60, 75. And as explained above, triable issues of fact exist as to Plaintiff’s status with respect to Jefferson.

Thus, the Court denies the motion as to this issue.

4.      Cross-Complaint’s Fourth Cause of Action Breach of Fiduciary Duty

Plaintiff contends that he has been and is a member and manager of Jefferson and has exercised business judgment in good faith. Further, he again contends that Upchurch has no standing to assert this claim.

A fiduciary owes duties of care. E.g., Salahutdin v. Valley of Cal., Inc. (1994) 24 Cal.App.4th 555, 563. “The presumption created by the business judgment rule is not absolute. ” Bezirdjian v. O'Reilly (2010) 183 Cal.App.4th 316, 323. “‘The business judgment rule does not shield actions taken without reasonable inquiry, with improper motives, or as a result of a conflict of interest.’”  Kruss v. Booth (2010) 185 Cal.App.4th 699, 728. “In most cases, ‘the presumption created by the business judgment rule can be rebutted only by affirmative allegations of facts which, if proven, would establish fraud, bad faith, overreaching or an unreasonable failure to investigate material facts.’” Berg & Berg Enterprises, LLC v. Boyle (2009) 178 Cal.App.4th 1020, 1046.

Here, the circumstances in evidence reasonably infer that Plaintiff acted with improper motives to take financial advantage of one having severe mental and physical problems, thereby creating an issue for the factfinder to resolve one way or the other. E.g., Russell Glazer decl., ex. 2 (Plaintiff’s special interrogatory responses), pp. 28-31.

Thus, the Court denies the motion as to this issue.

5.      Cross-Complaint’s Fifth Cause of Action for Elder and Dependent Adult Financial Abuse

Plaintiff argues that this claim is barred by the statute of limitations. Also he asserts that Ms. Upchurch-Friedman was not a dependent adult and not exploited. In support, Plaintiff filed a request for judicial notice of her birthdate.

Claims under the Elder Abuse Act have a two-year statute of limitations. Samantha B. v. Aurora Vista Del Mar, LLC (2022) 77 Cal.App.5th 85, 96 (citing Code Civ. Proc., § 335.1). Generally, this type of claim involves financial abuse or neglect of an elder or dependent. E.g., Carter v. Prime Healthcare Paradise Valley LLC (2011) 198 Cal.App.4th 396, 407.

The Court determines that there are triable issues of material fact as to whether the Statute of Limitations expired as to an entire cause of action. See Def’s Response to Pl’s UMF Nos. 144; Def and Cross-Complainant’s Add’l Material Facts Nos. 174-192. For example, as to when Plaintiff should have known of claim accrual, while an attorney had mailed a letter for Plaintiff not to have any contact with Ms. Upchurch-Friedman, it was only equivocal about Plaintiff continuing with business participation, until that issue unequivocally arose later. See, e.g., Russell Glazer Decl., Exs. 12 (6/15/15 letter to Plaintiff) and 13 (6/30/15 letter from Plaintiff about continuing with business participation).

Also, there are disputes about whether Ms. Upchurch-Friedman was a dependent adult financially abused. Def and Cross-Complainant’s Add’l Material Facts Nos. 174-192. For example, Plaintiff’s interrogatory responses infer that Plaintiff at some point discovered she has a heavy drinker, manic depressive and in financial distress, while Plaintiff continued to enter into financial arrangements with her. See Russell Glazer Decl., Ex. 2 (Plaintiff’s special interrogatory responses), pp. 28-31. Such disputes are properly raised in opposition, because the Cross-Complaint, paragraph 73, alleges a dependent adult, and not just one over 65 years old.

Thus, the Court denies the motion as to this issue.

CONCLUSION

Therefore, the Court denies the motion entirely, as to all noticed issues.