Judge: Armen Tamzarian, Case: 22STCV13981, Date: 2023-05-23 Tentative Ruling

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Case Number: 22STCV13981    Hearing Date: May 23, 2023    Dept: 52

Defendant State of California by and through the Department of Health Care Services’ Demurrer and Motion to Strike

Demurrer

Defendant State of California by and through the Department of Health Care Services demurs to the entire complaint by plaintiffs Christopher A. Altounian, Maria Margarita Carranza, and Luis H. Carranza.

The court notes that the first named plaintiff, Christopher A. Altounian, applied for a fee waiver, which was denied.  He did not timely pay the filing fee, so the complaint was voided as to him under Government Code § 68634(g).

Summary of Complaint

Plaintiffs’ complaint alleges a dispute between plaintiffs and the California Health and Human Services Agency regarding the In-Home Supportive Services (IHHS) program.  Under that program, the State pays or paid Altounian to serve as an in-home caretaker for the Carranzas.  The complaint alleges the State failed to pay Altounian $17,000 it owes to him. 

Based on these factual allegations, the complaint asserts various tort causes of action: (1) fraud, (2) check fraud, (3) conspiracy to commit misappropriation of government issued funding, (4) IHHS dismissal fraud, and (5) “infliction injuries.”  Attachments to the complaint also assert causes of action for common counts and general negligence.

Sovereign Immunity

Sovereign immunity bars each of the complaint’s causes of action against the State of California by and through the Department of Health Care Services.  “[A]ll government tort liability must be based on statute.”  (County of San Bernardino v. Superior Court (2022) 77 Cal.App.5th 1100, 1107.)  “ ‘[S]overeign immunity is the rule in California; governmental liability is limited to exceptions specifically set forth by statute.’ ”  (Id. at p. 1108.)  For example, Government Code section 835 provides that “a public entity is liable for injury caused by a dangerous condition of its property” in certain circumstances. 

Plaintiffs do not identify any authorizing statute that would make the State of California liable for the various torts alleged in the complaint. 

Moreover, the Government Code expressly provides immunity for fraud.  “A public entity is not liable for an injury caused by misrepresentation by an employee of the public entity, whether or not such misrepresentation be negligent or intentional.”  (Gov. Code, § 818.8.)  Plaintiffs allege various forms of intentional misrepresentation or concealment.  The State and its executive agencies cannot be liable for those torts.

Government Claims Act

Plaintiffs’ complaint also fails because it does not allege plaintiffs timely complied with the Government Claims Act.  Under that law, a plaintiff must present any claim for damages against the government before bringing a civil action.  (Gov. Code, § 905; City of Stockton v. Superior Court (2007) 42 Cal.4th 730, 737–738.)  “ ‘Claims for personal injury must be presented not later than six months after the accrual of the cause of action, and claims relating to any other cause of action must be filed within one year of the accrual of the cause of action.’ ”  (Willis v. City of Carlsbad (2020) 48 Cal.App.5th 1104, 1118.)  “With certain exceptions [citation], the timely filing of a written government claim is an element that a plaintiff is required to prove in order to prevail on his or her cause of action.”  (Id. at p. 1119.)

The complaint does not allege plaintiffs presented a claim to the State of California or the Department of Health Care Services for the damages they seek.  Doing so was required under the Government Claims Act.  Plaintiffs’ complaint therefore fails to allege sufficient facts to constitute a cause of action against the State.  

Motion to Strike

Defendant State of California by and through the Department of Health Care Services moves to strike the complaint’s exemplary damages attachment (form PLD-PI-001(6)).  A party may move to strike a “demand for judgment requesting relief not supported by the allegations of the complaint.”  (CCP § 431.10(b)(3).)  Courts may strike allegations related to exemplary or punitive damages when the plaintiff cannot recover them.  (Grieves v. Superior Court (1984) 157 Cal.App.3d 159, 164.)    

Punitive damages are not available against public entities.  “Notwithstanding any other provision of law, a public entity is not liable for damages awarded under Section 3294 of the Civil Code or other damages imposed primarily for the sake of example and by way of punishing the defendant.”  (Gov. Code, § 818.)  The State of California by and through the Department of Health Care Services is a public entity.  It cannot be liable for punitive damages.

After a successful challenge to 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.)  Leave to amend should be denied where “no liability exists under substantive law.”  (Lawrence v. Bank of America (1985) 163 Cal.App.3d 431, 436.)  As a matter of substantive law, the State of California cannot be liable for exemplary damages.  The court therefore will grant the motion to strike without leave to amend. 

Plaintiffs’ Request for Entry of Default

Plaintiffs argue this demurrer and motion to strike are untimely.  Plaintiffs contend the clerk should have granted their request for entry of defendant’s default.  (Plaintiffs did not file proof of serving these papers on defendant.)

The clerk properly rejected entry of this defendant’s default.  The clerk’s notice of rejection dated March 24, 2023, gives several reasons: “All Plaintiffs must be named on Section 1b.  Proof of Service filed on March 01 2023.  Section 3a Only one named Defendant and no Does can be named.  Defendants to be served separately.  Authorized Agent or Authorized to Accept must be named.  Security not acceptable.  If full name not presented must have 5 Physical Descriptions for Joe.  Manner of Service not clear it states it was substituted and Personal was attached to it as well.  Proof of Mailing required for Substituted Service.  Amendment to Complaint must be served to Defendant along with Summons and Complaint.”

Plaintiffs never filed valid proof of service of summons on defendant State of California by and through the Department of Health Care Services.  Plaintiffs have filed three proofs of service of summons in this action.  First, on June 13, 2022, plaintiffs filed proof of personal service on a different defendant.  The proof of service does not identify the party served (¶ 3.a) but indicates service was made at the address of the Board of Supervisors of the County of Los Angeles.

Second, on July 8, 2022, plaintiffs filed proof of service purporting to serve “CA Health/Human Services Legal Department at DHCS Office of Legal Services” by mail and acknowledgment of receipt of service under Code of Civil Procedure section 415.30.  That method of service requires return of a signed acknowledgment of receipt of summons on the mandatory Judicial Council of California form POS-015.  Plaintiffs did not file that.  Plaintiffs instead attached only a receipt showing they paid the United States Postal Service for express mail.

Finally, on March 1, 2023, plaintiffs filed proof of service of summons on “CA Health/Human Svcs.; D-IHHS; Does 1-10” by serving “Joe / Security” at 1501 Capital Ave., Sacramento, California 95814.  As the clerk stated, this proof of service is invalid for several reasons.  It does not show plaintiffs caused substituted service on “the person who is apparently in charge” of defendant’s office as required.  (CCP § 415.20(a).)  It does not state the process server “thereafter mail[ed] a copy of the summons and complaint.”  (Ibid.) 

Moreover, this proof of service does not clearly indicate that plaintiffs served this defendant, the State of California by and through the Department of Health Care Services.  Section 3.a of the proof of service indicates the party served was “CA Health/Human Svcs.; D-IHHS; Does 1-10.”  Plaintiffs did not attempt to name the Department of Health Care Services as a defendant until March 24, 2023.  On that day, they submitted an amendment to complaint seeking to correct the incorrect name “CA Dept Health/Human Svcs.” to “CA Dept of Health Care Services.”  As the form states, correcting a defendant’s name requires a court order.  Amending a complaint by “correcting a mistake in the name of a party” requires leave of court.  (CCP § 473(a)(1).)  The court did not sign that proposed order.

This demurrer and motion to strike are timely because plaintiffs never showed valid proof of service of summons on defendant State of California by and through the Department of Health Care Services.

Disposition

            Defendant State of California by and through the Department of Health Care Services’ demurrer to the entire complaint is sustained with 20 days’ leave to amend.

Defendant State of California by and through the Department of Health Care Services’ motion to strike is granted without leave to amend.  The court hereby strikes the complaint’s entire exemplary damages attachment (form PLD-PI-001(6)) without leave to amend.