Judge: Armen Tamzarian, Case: 23STCV20653, Date: 2023-11-09 Tentative Ruling

Case Number: 23STCV20653    Hearing Date: November 9, 2023    Dept: 52

Defendant FPI Management, Inc.’s Demurrer and Motion to Strike Portions of Plaintiff’s Complaint

Demurrer

Defendant FPI Management, Inc. demurs to all eight causes of action alleged by plaintiff Mez, Inc. doing business as Luxe Concierge and doing business as Luxe Security Services.

1st Cause of Action: Breach of Contract

Plaintiff alleges sufficient facts for this cause of action.  The elements are: “(1) the existence of the contract, (2) plaintiff’s performance or excuse for nonperformance, (3) defendant’s breach, and (4) the resulting damages to the plaintiff.”  (Oasis West Realty, LLC v. Goldman (2011) 51 Cal.4th 811, 821.)  A complaint alleging breach of contract “may plead the legal effect of the contract” and is not required to attach the contract or plead its terms verbatim.  (Construction Protective Services, Inc. v. TIG Specialty Ins. Co. (2002) 29 Cal.4th 189, 199.)

Plaintiff alleges the parties “entered into a written agreement wherein Plaintiff agreed to provide security guard services to Defendant FPI, a manager of residential real properties.”  (Comp., ¶ 13.)  Plaintiff alleges it performed under the agreement.  (¶ 14.)  It alleges defendant breached the contract “by failing and refusing to pay Plaintiff for the services.”  (¶ 15.)  It alleges plaintiff suffered damages in that defendant did not pay everything owed.  (¶¶ 15-16.) 

Defendant argues plaintiff fails to allege the relevant parties to the contract because FPI is a property manager, not a property owner, and does not allege which properties the contract applies to.  Plaintiff clearly alleges the parties to the contract: “Plaintiff and Defendant FPI and each of them, entered into a written agreement.”  (¶ 13.)  Whether FPI manages or owns the properties and the properties’ addresses are irrelevant.  This cause of action is crystal clear: defendant agreed to pay for services, plaintiff provided the services, and defendant did not pay.

2nd Cause of Action: Civil Code § 1719

            Defendant demurs to this cause of action on the basis that plaintiff did not allege it sent defendant a demand for payment via certified mail.  “In the case of a stop payment, a court may not award damages or costs under this section unless the court receives into evidence a copy of the written demand that, in that case, shall have been sent to the drawer and a signed certified mail receipt showing delivery, or attempted delivery if refused, of the written demand to the drawer’s last known address.”  (Civ. Code, § 1719(d).)  This subdivision refers to what the court must “receive[] into evidence,” not what the plaintiff’s complaint must allege.  Regardless, plaintiff’s complaint attaches and incorporates five written demands to make payment, each of which state “via certified mail (return receipt requested).” (Comp., ¶ 21, Ex. 1.)

3rd, 4th, and 5th Causes of Action: Common Counts

            Plaintiff alleges sufficient facts for the third cause of action for open account, the fourth cause of action for account stated, and the fifth cause of action for goods and services rendered.  These are three forms of common counts.  Rather than “a specific cause of action,” a common count “is a simplified form of pleading normally used to aver the existence of various forms of monetary indebtedness” often “used as an alternative way of seeking the same recovery demanded in a specific cause of action.”  (McBride v. Boughton (2004) 123 Cal.App.4th 379, 394.)  “The only essential allegations of a common count are ‘(1) the statement of indebtedness in a certain sum, (2) the consideration, i.e., goods sold, work done, etc., and (3) nonpayment.’ ”  (Farmers Ins. Exchange v. Zerin (1997) 53 Cal.App.4th 445, 460.) 

The complaint alleges all essential facts.  It alleges defendant owes it $253,752.  (Comp., ¶¶ 25, 28, 3233.)  It alleges plaintiff provided services: security at properties defendant managed.  (¶¶ 13-15.)  And it alleges defendant did not pay the $253,752 owed.  (¶¶ 26, 29, 33.)

Defendant’s demurrer relies on cases about the sufficiency of evidence, not the allegations of the complaint.  (Tsemetzin v. Coast Federal Savings & Loan Assn. (1997) 57 Cal.App.4th 1334, 1343 [plaintiff did not allege the theory of open book account, but summary judgment also proper because plaintiff “produced no evidence sufficient to raise a material issue of fact on the point”]; Maggio, Inc. v. Neal (1987) 196 Cal.App.3d 745, 752 [“no evidence of an agreement between the parties that the loans to Neal would be carried as a book account”] & 753 [“no evidence that Neal knew that he was indebted to Maggio or that he was aware that Maggio was maintaining an account which showed his increasing indebtedness”]; H. Russell Taylor's Fire Prevention Service, Inc. v. Coca Cola Bottling Corp. (1979) 99 Cal.App.3d 711, 728 [finding “sufficient evidence supporting the trial court’s conclusion that Taylor was barred from seeking relief on the basis of an open book account”].)  These cases do not support defendant’s argument that plaintiff’s complaint fails to state sufficient facts to constitute these causes of action.  

6th and 7th Causes of Action: Fraud and Negligent Misrepresentation

Plaintiff does not allege these causes of action with the required level of specificity.  “Fraud and negligent misrepresentation must be pleaded with particularity and by facts that  ‘ “ ‘show how, when, where, to whom, and by what means the representations were tendered.’ ” ’ ”  (Charnay v. Cobert (2006) 145 Cal.App.4th 170, 185, fn. 14.)  “ ‘This particularity requirement necessitates pleading facts which show how, when, where, to whom, and by what means the representations were tendered.’ ”  (Lazar v. Superior Court (1996) 12 Cal.4th 631, 645.)  “A plaintiff’s burden in asserting a fraud claim against a corporate employer is even greater.  In such a case, the plaintiff must ‘allege the names of the persons who made the allegedly fraudulent representations, their authority to speak, to whom they spoke, what they said or wrote, and when it was said or written.’ ”  (Ibid.) 

Intentional misrepresentation requires: “(a) misrepresentation; (b) defendant’s knowledge of the statement’s falsity; (c) intent to defraud (i.e., to induce action in reliance on the misrepresentation); (d) justifiable reliance; and (e) resulting damage.”  (Hunter v. Up-Right, Inc. (1993) 6 Cal.4th 1174, 1184.)  Negligent misrepresentation requires the same elements as intentional misrepresentation except for “knowledge of falsity.”  (Apollo Capital Fund, LLC v. Roth Capital Partners, LLC (2007) 158 Cal.App.4th 226, 243.)  It instead requires misrepresentation “without reasonable ground for believing it to be true.”  (Ibid.)

The complaint alleges, “In or about November 2022, Defendant FPI, by and through Joshua Moore, represented, warranted and promised to Plaintiff, via telephone calls and written communications, that occurred in Los Angeles, California, that they: (i) had the financial means and ability to enter into the Agreement and to pay for services rendered by Plaintiff; and (ii) they could and would pay Plaintiff in connection with the Agreement and the services rendered by Plaintiff.”  (Comp., ¶ 35.) 

Plaintiff thus alleges how, when, where, and by what means the misrepresentations were made.  Plaintiff also alleges the name of the person who made the representations and what he said.  The complaint does not, however, allege Joshua Moore’s authority to speak on behalf of defendant.  It makes no allegations about his relationship to defendant FPI Management, Inc. or how he is authorized to speak for it.  The complaint also does not allege the person to whom Moore spoke.  It only alleges he spoke “to Plaintiff,” a corporation.    

8th Cause of Action: Unjust Enrichment

Plaintiff does not allege sufficient facts for the eighth cause of action because the law does not recognize unjust enrichment as a cause of action, per se.  “[T]here is no cause of action in California for unjust enrichment.”  (Melchior v. New Line Productions, Inc. (2003) 106 Cal.App.4th 779, 793.)  “Unjust enrichment is ‘ “a general principle, underlying various legal doctrines and remedies,” ’ rather than a remedy itself.”  (Ibid.) 

Plaintiff argues unjust enrichment is equivalent to a “ ‘quasi-contract claim seeking restitution.’ ” (Opp., p. 11.)  But, for “quasi-contractual recovery … it is well settled that there is no equitable basis for an implied-in-law promise to pay reasonable value when the parties have an actual agreement covering compensation.”  (Hedging Concepts, Inc. v. First Alliance Mortgage Co. (1996) 41 Cal.App.4th 1410, 1419.)

Motion to Strike

            Defendant FPI Management, Inc. moves to strike paragraphs 34-47 of the complaint and its prayer for punitive and exemplary damages. 

Paragraphs 34-47

Defendant moves to strike all paragraphs under the sixth and seventh causes of action.  “Where a whole cause of action is the proper subject of a pleading challenge, the court should sustain a demurrer to the cause of action rather than grant a motion to strike.”  (Quiroz v. Seventh Ave. Center (2006) 140 Cal.App.4th 1256, 1281.)  The court will sustain the demurrer to the sixth and seventh causes of action.  Striking these paragraphs is unnecessary.

Prayer for Punitive Damages

The complaint does not allege sufficient facts to recover punitive 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).) 

Plaintiff’s claim for punitive damages relies on its fraud claim.  Punitive damages are available “[i]n an action for the breach of an obligation not arising from contract.”  (Civ. Code, § 3294, subd. (a).)  The court will sustain the demurrer to plaintiff’s causes of action for fraud and negligent misrepresentation.  The remaining causes of action allege breach of an obligation arising from contract.  They all arise from allegations that defendant did not pay what it owed under the parties’ written agreement. 

Plaintiff also does not allege sufficient facts to make defendant FPI Management, Inc. liable for punitive damages as a corporation.  Civil Code section 3294, subdivision (b) provides that for a corporate employer to be liable for punitive damages, “the advance knowledge and conscious disregard [of an employee’s unfitness], authorization, ratification or act of oppression, fraud, or malice must be on the part of an officer, director, or managing agent of the corporation.” 

The complaint alleges Joshua Moore committed the act of fraud.  (Comp., ¶ 35.)  It does not allege he was an officer, director, or managing agent of FPI Management, Inc.  Nor does it allege any officer, director, or managing agent of FPI Management, Inc. knew Joshua Moore was unfit or authorized or ratified Moore’s purported fraud.

Disposition

Defendant FPI Management, Inc.’s demurrer to plaintiff Mez, Inc.’s first through fifth causes of action is overruled.  Defendant FPI Management, Inc.’s demurrer to the sixth through eighth causes of action is sustained with 20 days’ leave to amend.

Defendant FPI Management, Inc.’s motion to strike is granted only as to the prayer for punitive damages.  The court hereby strikes the following portion of the complaint with 20 days’ leave to amend: “For punitive and exemplary damages in an amount to be determined at time of trial.”  (Comp., prayer ¶ 6, page 9, lines 3-4.)