Judge: Alison Mackenzie, Case: 23STCV20363, Date: 2024-02-05 Tentative Ruling



Case Number: 23STCV20363    Hearing Date: February 5, 2024    Dept: 55

NATURE OF PROCEEDINGS:  Plaintiffs’ Special Motion to Strike the Cross-Complaint of Cross-Complainants Mendy Ezagui and Mayta Malamud Pursuant to California Anti-Slapp Statute [C.C.P. §425.16].

The motion is denied.

BACKGROUND

JANET COHEN and JOSEPH COHEN (“Cross-Defendants”)) filed this case against MENDY EZAGUI and MAYTA MALAMUD (“Cross-Complainants”), alleging that Cross-Complainants breached their lease agreement for the residential property at 1115 S. Sherboume, Los Angeles, CA 90035 (“Property”), by failing to rent for the years 2020, 2021, and 2022.   

Cross-Complainants filed a Cross-Complaint seeking damages against Cross-Defendants for allegedly untenantable and substandard conditions at the Property. Cross-Complainants also allege that Cross-Defendants are involved in improper debt collection activities. Cross-Complainants’ causes of action are: 1) Breach of Contract; 2) Breach of Implied Warranty of Habitability / Tenantability; 3) Breach of Implied Warranty of Quiet Enjoyment; 4) Negligence; 5) Nuisance; 6) Intentional Infliction of Emotional Distress; and 7) Violation of the Rosenthal Fair Debt Collection Practices Act (“RFDCPA”).

Cross-Defendants now move to strike the Seventh Cause of Action in the Cross-Complaint pursuant to CCP § 425.16, which extends protections to strategic lawsuits against public participation (“SLAPP” actions). Cross Complainants oppose the motion.

COURT STRIKES UNAUTHORIZED ADDITIONAL FILINGS

The Court strikes the following documents filed after the parties completed briefing on the motion on 01/29/2024: (1) Amended Reply in Support of Special Motion to Strike (Anti-SLAPP), filed 2/1/2024; (2) Request for Judicial Notice in Support of Amended Reply, filed 2/1/2024; and (3) Response to Late Filed Reply, filed 2/1/2024. These documents were filed four days before the hearing, and after Cross-Defendants timely filed their reply on 1/29/2024.

The Court does not consider these unauthorized documents for purposes of this motion. Bozzi v. Nordstrom, Inc. (2010) 186 Cal. App. 4th 755, 765 (affirming court’s discretion to refuse to consider unauthorized “surrebuttal” briefs).

LEGAL STANDARD

A cross-defendant opposing a “strategic lawsuit against public participation” (“SLAPP”) claim may bring an “anti-SLAPP” special motion to strike any cause of action “arising from any act of that person in furtherance of the person’s right of petition or free speech under the United States Constitution or the California Constitution in connection with a public issue…” CCP § 425.16(b)(1).

Courts use a two-step process for considering anti-SLAPP motions. First, the cross-defendant must show that the acts of which the cross-complainant complains were protected activity, namely, that they were taken “in furtherance of the [cross-defendant’s] right of petition or free speech under the Unites States or California Constitution in connection with a public issue.” CCP § 425.16(b)(1).

“In determining whether the first step has been established, i.e. the ‘arising from’ element of the anti-SLAPP statute, a court must consider the pleadings and any supporting and opposing affidavits stating the facts upon which alleged liability is based.”  Gerbosi v. Gaims, Weil, West & Epstein, LLP (2011) 193 Cal.App.4th 435, 443-44.  Moving parties have the initial burden to demonstrate that a cause of action is subject to a special motion to strike. Martinez v. Metabolife Inter. Ins. (2003) 113 Cal.App.4th 181, 186. Specifically, courts decide whether moving parties have made a prima facie showing that the attacked claims arise from a protected activity, including defendants’ right of petition, or free speech, under a constitution, in connection with issues of public interest.  CCP §425.16(e); Healy v. Tuscany Hills Landscape & Recreation Corp., (2006) 137 Cal. App. 4th 1, 5.

If moving parties successfully have shifted the burden, then opposing parties must demonstrate a probability of prevailing on the merits of the complaint.  Equilon Ent., LLC v. Consumer Cause, Inc. (2002) 29 Cal.4th 53, 67. The prima facie showing of merit must be made with evidence that is admissible at trial.”  Salma v. Capon (2008) 161 Cal.App.4th 1275, 1289. 

 

ANALYSIS

Step 1 – SLAPP Applicability

Cross-Defendants assert that Cross-Complainants’ claim for violation of the RFDCPA is premised on Cross-Defendants’ filing of the Complaint, which is protected conduct.

A cross-complaint ordinarily would not be a SLAPP suit unless the cross-complaint alleges a cause of action arising from the plaintiff's act of filing the complaint, as opposed to one arising from the underlying dispute alleged in the complaint.  Third Laguna Hills Mutual v. Joslin (2020) 49 Cal.App.5th 366, 371-72.  This is because, by definition, a SLAPP suit is not related to the transaction or occurrence of the complaint, but instead is one that arises out of the litigation process itself.  Kajima Engineering & Construction, Inc. v. City of L.A. (2002) 95 Cal. App. 4th 921, 934 (“If a cross-defendant believes that a cross-complaint has been filed ‘for an improper purpose, ... or that the claims ... are frivolous ..., then it may move for sanctions.... The anti-SLAPP statute, however, is not the appropriate remedy.”). 

The Cross-Complaint allegations do not mention the Complaint as the basis for the claims, including for the seventh cause of action. Cross-Complainants allege that they endured substandard conditions at the Property, including water leads and damage, mold, and harassment by Cross Defendants. (Cross-Compl., ¶¶ 14-15.) Cross-Defendants allege that Cross-Defendants also withheld their security deposit and sent communications to them regarding debts allegedly owed for rent, repairs, incidentals, and other unspecified items. (Id., ¶ 88.) Cross-Complainants allege that Cross-Defendants falsely claimed that these amounts were due, and such conduct violates the RFDCPA. (Id., ¶¶ 89, 93.)

The declaration of Cross-Complainant Mendy Ezagui states that he and his family moved out in September 2022 after enduring the alleged substandard conditions and harassment. (Ezagui Dec., ¶¶ 5-6.) He states that after notifying Cross-Defendants that they were moving out, Cross-Defendants sent emails to Cross-Complainants attempting to collect monies allegedly owed for rent and repairs. (Id., ¶ 16, Ex. C.)

The gravamen of the seventh cause of action, therefore, centers on Cross-Complainants’ allegation that Cross-Defendants’ engaged in improper debt collection practices after subjecting Cross-Complainants to harassment and substandard living conditions, which ultimately led to Cross-Complainants moving out of the Property. Contrary to Cross-Defendants’ assertion, this claim is not based on the filing of the Complaint. Rather, it is a compulsory cross-complaint related to Cross-Defendants’ alleged improper conduct with respect to the Property.  

Cross-Defendants assert that the Court should, at a minimum, strike certain unidentified portions of the seventh cause of action. “[W]hile courts may strike less than the entirety of a complaint or pleaded cause of action, the trial court is not required to take on the burden of identifying the allegations susceptible to a special motion to strike.”  Park v. Nazari (2023) 93 Cal.App.5th 1099, 1109. In any event, nothing in the Complaint, including the seventh cause of action, references protected conduct.

Therefore, the motion fails to demonstrate applicability of the SLAPP statute as to the Cross-Complaint.

            Step 2 – Probability of Prevailing

Cross-Defendants assert that Cross-Complainants cannot show a probability of prevailing on their seventh cause of action because Cross-Defendants are not “debt collectors” under the definition of the relevant statute (Civil Code § 1788.2(c)) and because the Complaint is not an attempt to collect a consumer debt under Civil Code § 1788.2(f).

A court need not reach the second prong of the SLAPP analysis if the first prong (arising from protected conduct) was not satisfied.  Wang v. Wal-Mart Real Estate Business Trust (2007) 153 Cal.App.4th 790, 801. Here, Cross-Defendants failed to meet their burden on the first prong of the SLAPP analysis and so Cross-Complainants do not have a burden to show a probability of prevailing. But even if Cross-Complainants did have the burden, they have established a probability of prevailing.

 

The burden on the non-moving party in an anti-SLAPP motion is like that of a party opposing a motion for summary judgment. DaimlerChrysler Motors Co. v. Lew Williams, Inc. (2006) 142 Cal.App.4th 344, 352. Whether complainants have satisfied their burden is a question of law.  Wilson v. Parker, Covert & Chidester (2002) 28 Cal.4th 811, 821. 

The elements of a claim for violating the RFDCPA are:

  1. Plaintiff was the object of collection activity arising from consumer debt;
  2. defendant is a debt collector as statutorily defined;  and
  3. defendant engaged in a prohibited act or omission (e.g., actual or attempted collecting from a debtor on a consumer debt, in harassing or threatening manner).

O'Neil-Rosales v. Citibank (S. Dakota) N.A. (2017) 11 Cal. App. 5th Supp. 1, 7  (citing Civ. C. §§ 1788.10-1788.12, 1788.14-1788.16).  See also  Davidson v. Seterus, Inc. (2018) 21 Cal. App. 5th 283, 295-96  (RFDCPA prohibits debt collectors’ unfair or deceptive acts in collecting consumer debts, and “a debt collector is a person who regularly engages in the act or practice of collecting money, property or their equivalent that is due or owing by a natural person as a result of a transaction between that person and another person, in which the natural person acquired property, services, or money on credit, primarily for personal, family, or household purposes.”).

 

In a SLAPP motion, to establish a probability, a plaintiff must demonstrate that the complaint is both legally sufficient and supported by a prima facie showing of facts, which, if credited by the trier of fact, is sufficient to sustain a favorable judgment. Morrow v. Los Angeles Unified School Dist. (2007) 149 Cal.App.4th 1424, 1435; Navellier v. Sletten (2002) 29 Cal.4th 82, 88. “The plaintiff need only establish that his or her claim has ‘minimal merit’…to avoid being stricken as a SLAPP.”  Soukup v. Law Offices of Herbert Hafif (2006) 39 Cal.4th 260, 291.  

The allegations in the Cross-Complaint sufficiently allege that Cross-Complainants are debtors and that Cross-Defendants sought to coerce Cross-Complainants to pay monies that they claimed Cross-Complainants owed them. (Cross-Compl., ¶¶ 79, 80, 84-86, 88, 90.) Cross-Defendants are a “debt collector” because they allegedly engaged in conduct to collect such debts from Cross-Complainants. (Id., ¶ 81.) And the Cross-Complaint adequately alleges that Cross-Defendants engaged in conduct that violates the RFDCPA. (Id., ¶¶ 87-93.)

The Ortiz opinion cited by Cross-Defendants is not on point or helpful, as to whether rent collection is a debt collector’s collection of consumer debts, because it distinguishably addresses credit report information, a lease agreement, and a different statute, and not rent collection activities or the RFDCPA. See Ortiz v. Lyon Management Group, Inc. (2007) 157 Cal.App.4th 604, 618, 619, overruled on other grounds by First Student Cases (2018) 5 Cal. 5th 1026, 1038. 

 

 

Cross-Defendants also endeavor to show that there is no probability of prevailing because the litigation privilege applies to filing the Complaint. Generally, courts “decline to apply the litigation privilege to most debt collection legal actions involving violations of the Rosenthal Act.” Moten v. Transworld Sys. Inc. (2023) _ Cal.App.5th _, _, 2023 WL 9103620, at *9  (citing Minser v. Collect Access, LLC (2023) 92 Cal.App.5th 781, 791-92).  See also  Cabral v. Martins (2009) 177 Cal.App.4th 471, 487 (litigation privilege is inapposite to claims under the Rosenthal Act re debt collection);  Komarova v. National Credit Acceptance, Inc. (2009) 175 Cal.App.4th 324, 339 (debt collection outside of court is privileged, if done in connection with a judicial proceeding to achieve the object of the litigation or contemplated litigation under serious consideration). The seventh cause of action for violation of RFDCPA simply does not fall within the scope of the litigation privilege, as several decisions have opined in well settled law.

Conclusion

The SLAPP motion is denied.