Judge: Armen Tamzarian, Case: 22STCV34822, Date: 2023-04-06 Tentative Ruling

Case Number: 22STCV34822    Hearing Date: April 6, 2023    Dept: 52

Defendants County of Los Angeles and Los Angeles County Flood Control District’s Demurrer and Motion to Strike Portions of First Amended Complaint

I. Demurrer

            Defendants County of Los Angeles and Los Angeles County Flood Control District demur to all four causes of action alleged in the first amended complaint by plaintiff Perry Lazar, as an individual and as trustee of the Plone Trust.

First Three Causes of Action: Sovereign Immunity

            Plaintiff’s first cause of action for negligence, second cause of action for “violation of statutes,” and third cause of action for negligent hiring fail due to sovereign immunity.  “[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.)

Plaintiff argues defendants are liable under Government Code section 815.2(a), which provides, “A public entity is liable for injury proximately caused by an act or omission of an employee of the public entity within the scope of his employment if the act or omission would, apart from this section, have given rise to a cause of action against that employee.”  This statute codifies public entities’ vicarious liability under the “doctrine of respondeat superior.”  (Mary M. v. City of Los Angeles (1991) 54 Cal.3d 202, 209.)  Defendants can thus only liable if their individual employees would be liable.  “[A] public employee is liable for injury caused by his act or omission to the same extent as a private person.”  (Gov. Code, § 820(a).) 

The first amended complaint does not allege facts that would constitute a cause of action for negligence against defendants’ employees.  For negligence, a public entity employer can only be liable if its employees breached a common law duty of care to the plaintiff.  (Hoff v. Vacaville Unified School Dist. (1998) 19 Cal.4th 925, 933.) 

The first amended complaint does not allege defendants’ employees breached any duties owed to plaintiff.  The gravamen of the first two causes of action is that between 1966 and 1980, defendants negligently created a parcel of real property, parcel 36, without following the required procedures.  (FAC, ¶¶ 11-16, 19-24, 26.)  Plaintiff purchased parcel 36 in 2004.  He alleges that due to defendants’ negligence in creating the parcel decades before he purchased it, he has suffered various harms including a cloud on title.  (FAC, ¶¶ 16, 24, 26.)  Plaintiff cites no authority that public employees owe a duty to all future purchasers of land to comply with these required procedures, such as “to accept as a dedication a proper parcel or divide the property by way of a parcel map approved and reviewed by the county engineer.”  (FAC, ¶ 12.)  None of the breaches of duty plaintiff alleges would suffice for a claim of negligence against defendants’ individual employees.  Defendants therefore cannot be vicariously liable. 

With respect to the second cause of action for “violation of statutes,” none of the included statutes permit a private right of action or an exception to the general rule of sovereign immunity.  Plaintiff instead argues the statutes serve as a basis for negligence per se—meaning he claims tort liability.  The analysis for the first cause of action for negligence thus applies equally to the second cause of action. 

Plaintiff’s third cause of action alleges negligent hiring and supervision of several individually identified employees.  (FAC, ¶ 26.)  “[N]o statute provides” for a public entity’s “direct liability” for negligent hiring.  (C.A. v. William S. Hart Union High School Dist. (2012) 53 Cal.4th 861, 869.)  And without “a special relationship,” such as that between schools and students, a public entity’s employees have “no individual liability to third parties for negligent hiring, retention or supervision.”  (Id. at p. 877.)  Plaintiff does not allege facts showing any special relationship with defendants or their employees.  He therefore fails to allege sufficient facts for negligent hiring and supervision.

Fourth Cause of Action for Trespass

Defendants contend plaintiff’s fourth cause of action for trespass is untimely.  Plaintiff alleges sufficient facts to invoke the continuing trespass theory, an exception to the statute of limitations.  The continuing nuisance or trespass theory allows for deferral of the starting date of the statute of limitations.” (Chevron U.S.A. Inc. v. Superior Court (1994) 44 Cal.App.4th 1009, 1017.)  Under the “ ‘abatability test’ [citation], a trespass or nuisance is continuing if it ‘can be remedied at a reasonable cost by reasonable means.’ ”  (Madani v. Rabinowitz (2020) 45 Cal.App.5th 602, 609 (Madani).) 

Defendants argue this rule does not apply because the alleged trespass includes a “cement channel and attached fence [that] cross several blocks,” and plaintiff cannot show “a cement channel can be moved ‘at a reasonable cost’ and ‘by reasonable means.’ ”  (Reply, pp. 6-7.)  But the first amended complaint also alleges defendants trespassed by building a fence on plaintiff’s property.  “County has fenced in all of lot 84 and beyond said lot without permission or authority onto Lazar’s property preventing access to Lazar’s property.”  (FAC, ¶ 29.) 

Madani held that a fence estimated to “cost approximately $5,000 to $6,000 to move” constituted a continuing trespass.  (Madani, supra, 45 Cal.App.5th at p. 609.)  Likewise, when liberally construed and drawing inferences favoring plaintiff, the first amended complaint alleges defendants’ fence constitutes a continuing trespass.    

Disposition   

            Defendants County of Los Angeles and Los Angeles County Flood Control District’s demurrer to the first, second, and third causes of action is sustained with 20 days’ leave to amend.  Defendants’ demurrer to the fourth cause of action is overruled.

II. Motion to Strike

Defendants County of Los Angeles and Los Angeles County Flood Control District move to strike three portions of the first amended complaint alleging plaintiff’s “other damages.”  Courts may strike a “demand for judgment requesting relief not supported by the allegations of the complaint.”  (Code Civ. Proc., § 431.10, subd. (b)(3).)

First, defendants move to strike the entire paragraph 11(g): “Other damage: Lack of access to property, costs in legalizing/legitimizing Parcel 36, loss of sale of property, loss of value, payment of maintenance and taxes, cost of defending property rights, unjust enrichment, fees and costs, and any other relief the court deems proper.”  Defendants fail to show that plaintiff can recover none of these “other damages.”  As discussed above, plaintiff alleges sufficient facts to constitute a cause of action for trespass.  He can recover at least some of these “other damages” for trespass.

Second, defendants move to strike the language “payment of … taxes.”  They contend plaintiff cannot recover damages for payment of taxes because that remedy is exclusive to a cause of action for a tax refund, which he did not allege.  Plaintiff concedes that is the law in general, but argues he does not seek a tax refund and instead seeks various damages for negligent creation of the subject parcel.  Alleging damages in the form of “payment of … taxes” means plaintiff was damaged because he paid taxes.  Any damages would be the amount he paid in taxes over what he should have paid.  To recover that would be a tax refund.  That he also seeks other damages does not mean he can recover damages for “payment of … taxes.”

In the section on unjust enrichment, plaintiff’s opposition argues he “has been taxed for property which is allegedly held by an agent of the State of California and is not taxable pursuant to the Constitution of the State of California.  California Constitution Article XIII, §3.  Thus, Lazar’s damages in the payment of taxes and maintenance of property that he does not own due to the negligent acts of the defendants.”  (Opp., p. 9.)  This argument amounts to saying defendants’ negligence resulted in him paying too much in taxes.  His exclusive remedy for that specific portion of his damages is an action for a tax refund.

Third, defendants move to strike the language “unjust enrichment” from paragraph 11(g).  They argue “unjust enrichment is not a standalone cause of action.”  (Motion, p. 12.)  That is true.  “Unjust enrichment is ‘ “a general principle, underlying various legal doctrines and remedies,” ’ rather than a remedy itself.”  (Melchior v. New Line Productions, Inc. (2003) 106 Cal.App.4th 779, 793.)  It is “synonymous with restitution.”  (Durell v. Sharp Healthcare (2010) 183 Cal.App.4th 1350, 1370.) 

Disposition

            Defendants’ motion to strike is granted in part with 20 days’ leave to amend.  The court hereby strikes the following language from the first amended complaint: “and taxes” and “unjust enrichment.”  (Page 3, ¶ 11.g.)