Judge: Armen Tamzarian, Case: 21STCV34739, Date: 2023-01-25 Tentative Ruling

Case Number: 21STCV34739    Hearing Date: January 25, 2023    Dept: 52

Defendant American Honda Motor Co., Inc.’s Motion for Judgment on the Pleadings

Defendant American Honda Motor Co., Inc. moves for judgment on the pleadings on plaintiff Abbas Torabian’s sixth cause of action for fraudulent inducement.  This cause of action requires: (1) defendant omitted, concealed, or suppressed a material fact; (2) defendant had a duty to disclose the fact to plaintiff; (3) defendant intentionally omitted or concealed the fact with intent to defraud plaintiff; (4) plaintiff must have been unaware of the fact and would have acted otherwise if he had known of the concealed fact; and (5) the omission caused damages.  (Boschma v. Home Loan Center, Inc. (2011) 198 Cal.App.4th 230, 248.)  A cause of action for fraud requires specifically pleading each element.  (Alfaro v. Community Housing Improvement System & Planning Assn., Inc. (2009) 171 Cal.App.4th 1356, 1384 (Alfaro).)

            Plaintiff again fails to specifically allege facts for the final element: his reliance on any concealment caused damages.  A plaintiff must “allege specific facts not only showing he or she actually and justifiably relied on the defendant’s misrepresentations, but also how the actions he or she took in reliance on the defendant’s misrepresentations caused the alleged damages.”  (Rossberg v. Bank of America, N.A. (2013) 219 Cal.App.4th 1481, 1499.) 

Plaintiff’s third amended complaint alleges defendant concealed that 2018-2019 Honda Odyssey vehicles “contain a defective integrated in-vehicle communication, navigation, and entertainment system – commonly referred to as an ‘infotainment system’ – that causes many of the Vehicles’ features (e.g., navigation system, rear-entertainment system, audio system, backup camera, cabin watch system) to malfunction.  As a result of the defect, Honda Vehicles’ infotainment systems frequently freeze or crash (in which case no features connected to [the] system are operational, including the navigation technology, the radio, and the rearview camera).”  (3AC, ¶ 60.) 

Defendant’s alleged concealment of a defect in the infotainment system can only cause plaintiff damages if that defect is present in his vehicle and it harmed him.  Plaintiff does not specifically allege that.  Plaintiff’s third amended complaint now alleges some details about two times he presented the vehicle for repairs.  In October 2019, plaintiff presented the vehicle “with various concerns, including infotainment concerns.”  (3AC, ¶ 21.)  “[T]he audio system … required an upgrade as the audio system was malfunctioning.  The authorized repair facility performed repairs.”  (Ibid.)  In October 2020, plaintiff again presented the vehicle “with various concerns, including infotainment concerns.”  (Id., ¶ 22.)  “Recalls 20-050 and 20-051 were performed. These recalls required the rear view camera to be replaced as the image was blacked out and the audio unit to be updated again as it was still malfunctioning.  The authorized repair facility performed repairs.”  (Ibid.)     

Plaintiff’s alleged reliance on defendant concealing the infotainment system defect cannot cause damages if defendant repaired the defect without charging plaintiff.  Plaintiff does not allege he was charged for any repairs. 

As for current problems with the vehicle, plaintiff makes only vague and opaque allegations.  The third amended complaint alleges, “Thereafter, Plaintiff continued to experience symptoms of the infotainment defects and other defects despite Defendant’s representations that the various defects were repaired.”  (3AC, ¶ 23.)  It further alleges that “the Vehicle continued to exhibit symptoms of the defects following Defendant’s unsuccessful attempts to repair it.”  (Id., ¶ 24.) 

These allegations suffice for claims under the Song-Beverly Act but not for fraud, which must be specifically pleaded.  As the court stated when sustaining the demurrer to plaintiff’s second amended complaint: “A specific allegation would be, for example, that plaintiff’s vehicle’s infotainment system currently does not display the view from the backup camera. …  If indeed plaintiff’s infotainment system is currently malfunctioning, or has ever malfunctioned, plaintiff can easily say so in a clear, specific, and straightforward manner.”  (June 14, 2022 minute order, p. 3.) 

Plaintiff has not alleged what is currently wrong with the vehicle in a clear, specific, or straightforward manner.  He alleges he “continued to experience symptoms of the infotainment defects and other defects” (3AC, ¶ 23) and the vehicle “continued to exhibit symptoms of the defects” (id., ¶ 24).  He does not allege what symptoms he experienced after the repairs in October 2020.  He does not allege, for example, that the rearview camera’s image continues to black out or that the infotainment system freezes or crashes frequently.

The rule of relaxed specificity for fraudulent omission or concealment does not apply.  The specificity requirement does not fully apply to cases of omission or concealment nondisclosure because it is difficult to show “how” and “by what means” something did not happen.  (Alfaro, supra, 171 Cal.App.4th at p. 1384.)  Unlike omissions, defects or damages happen.  Plaintiff knows at least as much as defendant about the condition of his vehicle and what damages, if any, he has suffered.  Plaintiff fails to state facts in his third amended complaint that clearly answer these questions.      

Leave to Amend

            After a successful motion for judgment on the pleadings, where “there is a reasonable possibility that the defects can be cured by amendment, leave to amend must be granted.”  (Stevens v. Superior Court (1999) 75 Cal.App.4th 594, 601.)  The plaintiff bears the burden of “demonstrat[ing] how the complaint can be amended.”  (Smith v. State Farm Mutual Automobile Ins. Co. (2001) 93 Cal.App.4th 700, 711.)  “Leave to amend should be denied where the facts are not in dispute and the nature of the claim is clear, but no liability exists under substantive law.”  (Lawrence v. Bank of America (1985) 163 Cal.App.3d 431, 436.)

Plaintiff has not shown a reasonable possibility of amending the complaint to cure its defect.  Plaintiff already amended the complaint three times.  In its order sustaining the demurrer to the second amended complaint, the court gave specific examples of how plaintiff could cure the defect.  He has not done so.  Plaintiff has made no offer of proof as to specific facts he could allege to cure the defect.  If he could specifically allege such facts, he would have done so by now.

Disposition

            Defendant American Honda Motor Co.’s motion for judgment on the pleadings on plaintiff Abbas Torabian’s sixth cause of action for fraud is granted without leave to amend.