Judge: Armen Tamzarian, Case: 22STCV18103, Date: 2023-02-03 Tentative Ruling
Case Number: 22STCV18103 Hearing Date: February 3, 2023 Dept: 52
Defendant Mauricio
Aguilar’s Demurrer and Motion to Strike Complaint
Defendant
Mauricio Aguilar demurs to plaintiff Convertibles Only, Inc. dba Heritage
Classics’ complaint. A demurrer “test[s] the legal sufficiency of
a complaint.” (Donabedian v. Mercury
Ins. Co. (2004) 116 Cal.App.4th 968, 994.) In ruling on a demurrer, courts “assume
that the complaint’s properly pleaded material allegations are true and give
the complaint a reasonable interpretation by reading it as a whole and all its
parts in their context” but do not “assume the truth of contentions,
deductions, or conclusions of fact or law.” (Moore v. Regents of University
of California (1990) 51 Cal.3d 120, 125.)
Plaintiff’s complaint alleges three causes
of action: (1) conversion, (2) violation of Penal Code § 496, and (3) claim and
delivery. All three causes of action
arise from the allegation that plaintiff owns a specialized race car, which defendant
possesses.
Defendant Aguilar demurs primarily on the
basis that plaintiff lacks standing to assert any claims regarding the vehicle. He argues plaintiff does not “have any rights
to file a complaint on behalf of Bruno Lafitte.” Plaintiff has the right to file this
complaint on its own behalf. The
complaint alleges plaintiff sold the car to Lafitte, but retained a security
interest in it. (Comp., ¶ 10, Ex. 1.) Plaintiff further alleges that “title to the
Vehicle was transferred back to Plaintiff by Bruno Lafitte” later. (Id., ¶ 13.) The complaint includes a certificate of title
showing a transfer date of November 5, 2020, to registered owner “Heritage
Classics.” (Id., Ex. 2.)
Plaintiff is not suing on behalf of Bruno
Lafitte. The complaint alleges Lafitte
no longer owns the vehicle. Plaintiff now
owns it. Accepting the complaint’s
allegations as true, plaintiff shows it is entitled to immediate possession of
the vehicle as required for its three causes of action.
Defendant
also argues plaintiff wants to retrieve the vehicle “without paying the fee due
on the vehicle and the storage fee accrued by the buyer.” This argument improperly relies on factual
assertions outside the complaint. “A demurrer can be used only to challenge
defects that appear on the face of the pleading under attack … . No other extrinsic evidence can be
considered.” (Kerivan v. Title Ins.
& Trust Co. (1983) 147 Cal.App.3d 225, 229.) “ ‘A demurrer can be utilized where the
complaint itself is incomplete or discloses some defense that would bar
recovery.’ ” (Estate of Moss (2012)
204 Cal.App.4th 521, 535.)
Moreover,
even if these assertions were proper on demurrer, they would not be
relevant. They are not part of the
elements of plaintiff’s causes of action.
Rather than a defect in plaintiff’s complaint, this argument concerns a
dispute between defendant Aguilar and Lafitte.
That someone else owes Aguilar money does not negate plaintiff’s right
to immediate possession of the vehicle as alleged in the complaint.
Motion
to Strike
Defendant’s
motion is labeled a demurrer and motion to strike. A
typical motion to strike seeks to strike specified portions of a
complaint. (Code Civ. Proc., §§
435(b)(1), 436(a).) Defendant does not
seek to strike any portion of the complaint.
Defendant’s motion to strike merely duplicates the demurrer and fails
for the same reasons.
Disposition
Defendant Mauricio Aguilar’s
demurrer is overruled. Defendant
Mauricio Aguilar’s motion to strike is denied. Defendant Mauricio Aguilar is ordered
to answer within 20 days.