Judge: Armen Tamzarian, Case: 24STCV06424, Date: 2024-08-30 Tentative Ruling

Case Number: 24STCV06424    Hearing Date: August 30, 2024    Dept: 52

Tentative Ruling:

Pro Hac Vice Application of Peter N. Farley to Appear as Counsel for Defendant Trea SH Brockman, LLC

The application to admit Peter N. Farley to appear as counsel pro hac vice for plaintiff defendant Trea SH Brockman, LLC is granted.


Tentative Ruling:

            Defendant Trea SH Brockman, LLC’s Demurrer

Defendant Trea SH Brockman, LLC demurs to the second, third, and fourth causes of action alleged in the complaint by plaintiff BHFC Operating, LLC, dba Bottega Louie.

Economic Loss Rule

Defendant argues the economic loss rule bars plaintiff’s second cause of action for general negligence, third cause of action for “intentional tort,” and fourth cause of action for fraud.  The economic loss rule does not bar plaintiff’s second cause of action for general negligence.  Because the court will sustain the demurrer to the third and fourth causes of action for other reasons, the court does not reach the issue of whether the economic loss rule applies to those causes of action. 

Under the economic loss rule, generally “there is no recovery in tort for negligently inflicted ‘purely economic losses,’ meaning financial harm unaccompanied by physical or property damage.”  (Sheen v. Wells Fargo Bank, N.A. (2022) 12 Cal.5th 905, 922 (Sheen).)  “[T]he rule functions to bar claims in negligence for pure economic losses in deference to a contract between litigating parties.”  (Ibid.)

Plaintiff’s second cause of action alleges defendant violated the same duties as in the first cause of action for breach of contract.  Both causes of action arise from a contract between the parties: a commercial lease titled the “First Amendment to Retail Lease Agreement.”  (Comp., p. 5.)  The first cause of action for breach of contract alleges defendants “have failed, and continue to fail to properly maintain, provide and repair the leasehold premises” and thereby “continues to cause water intrusion.”  (Id., p. 4.) 

The second cause of action for general negligence alleges defendant “negligently maintained, installed, designed, repaired the property/real property/common areas, which are the subject of this action, so as the same are in disrepair, neglect, defective, not fit for commercial use and subject to water intrusion and other defective conditions and damages.”  (Comp., p. 5.)  It further alleges “Water Remediation Work performed pursuant to … the First Amendment to Retail Lease Agreement … has been performed negligently and incompetently.”  (Ibid.) 

In substance, these factual allegations amount to negligent performance of contractual duties.  Plaintiff therefore can only bring a negligence claim if it alleges physical or property damage to something other than the subject of the contract.

Plaintiff adequately alleges such property damage.  The complaint alleges defendant’s negligence caused damage because “floods destroy[ed] Plaintiff’s ceilings and moulding, host and server stations, and the patisserie, among other things.”  (Comp., p. 5.) 

Defendant argues that “damage to the property that is the subject of the lease is the proper subject of a breach of contract claim, not a tort claim.”  (Reply, p. 3.)  Defendant analogizes the premises to the product itself in a products liability case, where “ ‘the economic loss rule allows a plaintiff to recover in strict products liability in tort when a product defect causes damage to “other property,” that is, property other than the product itself.  The law of contractual warranty governs damage to the product itself.’ ”  (Robinson Helicopter Co., Inc. v. Dana Corp. (2004) 34 Cal.4th 979, 989.)

Assuming defendant correctly applies this doctrine to a lease contract, it is not clear from the face of the complaint that the things allegedly damaged are part of the premises themselves.  On demurrer, the court must liberally construe the complaint in favor of the plaintiff.  (Perez v. Golden Empire Transit Dist. (2012) 209 Cal.App.4th 1228, 1238).  While “ceilings and moulding” seem to be part of the premises (and perhaps not even plaintiff’s property), the court must construe the allegation that defendant caused damage to “host and server stations, and the patisserie” to constitute damages to plaintiff’s personal property that was not itself the subject of the lease. 

Second Cause of Action for General Negligence

            Defendant also demurs to the second cause of action on the grounds that plaintiff does not allege sufficient facts for duty.  For negligence, “[a] ‘ duty may arise through statute, contract, or the relationship of the parties.’ ”   (Lichtman v. Siemens Industry Inc. (2017) 16 Cal.App.5th 914, 920.)  “The general rule in California is that ‘[e]veryone is responsible ... for an injury occasioned to another by his or her want of ordinary care or skill in the management of his or her property or person....’ ”  (Cabral v. Ralphs Grocery Co. (2011) 51 Cal.4th 764, 771.)  “[I]n the absence of a statutory provision establishing an exception to the general rule of Civil Code section 1714, courts should create one only where ‘clearly supported by public policy.’ ”  (Ibid.)

Defendant’s argument on duty relies on Sheen, which concluded the law does not “impose a tort duty on a contracting party to avoid negligently causing monetary harm to another party to that contract.”  (Sheen, supra, 12 Cal.5th at p. 938.)  There, the California Supreme Court applied the economic loss rule.  The Court reasoned,the rationales behind the economic loss rule provide a compelling basis to reject ‘a duty of care’ ” under the circumstances.  (Id. at p. 942.)  As discussed above, the economic loss rule does not apply here.  Plaintiff alleges defendant’s negligence caused damage to plaintiff’s personal property.  Defendant does not show grounds for any exception to the general rule that everyone owes a duty not to harm to others.    

Third Cause of Action for “Intentional Tort”

            Plaintiff’s third cause of action for “intentional tort” is uncertain or, in the alternative, does not allege sufficient facts to constitute a cause of action.  “Demurrers for uncertainty are disfavored, and are granted only if the pleading is so incomprehensible that a defendant cannot reasonably respond.”  (A.J. Fistes Corp. v. GDL Best Contractors, Inc. (2019) 38 Cal.App.5th 677, 695, internal quotes and alterations omitted.)  The complaint must sufficiently apprise defendants of the claims against them.  (Ibid.) 

“Intentional tort” is a category of causes of action.  It is not a cause of action itself.  The factual allegations plaintiff makes for this cause of action are equivalent to those alleged for other cause of action.  A cause of action is subject to demurrer when “it merely duplicates” other causes of action.  (Shoemaker v. Myers (1990) 52 Cal.3d 1, 24.)  In Award Metals, Inc. v. Superior Court (1991) 228 Cal.App.3d 1128, 1135, the court stated a cause of action “labeled ‘Intentional Tort’ ” was “merely a duplication of” another cause of action.  The court found that, while the “demurrer was properly overruled as to” the latter cause of action, it “should have been sustained as to” the cause of action labeled “Intentional Tort.”  (Ibid.)  The same reasoning applies here. 

Fourth Cause of Action for Fraud

            Plaintiff does not allege fraud with the specificity required.  “Fraud must be pleaded with specificity rather than with ‘ “general and conclusory allegations.” ’  [Citation.]  The specificity requirement means a plaintiff must allege facts showing how, when, where, to whom, and by what means the representations were made, and, in the case of a corporate defendant, the plaintiff must allege the names of the persons who made the representations, their authority to speak on behalf of the corporation, to whom they spoke, what they said or wrote, and when the representation was made.”  (West v. JPMorgan Chase Bank, N.A. (2013) 214 Cal.App.4th 780, 793 (West).)

Both parties in this action are business entities.  The complaint does not identify an individual who made misrepresentations on behalf of defendant or an individual to whom the misrepresentations were made.  Plaintiff’s opposition relies on the exception when the defendant has “superior knowledge” or that information was “uniquely within” defendant’s knowledge.  (Opp., p. 12.)  Plaintiff, not defendant, should have superior knowledge about which individual acting on plaintiff’s behalf received or heard the misrepresentations.  And as to any misrepresentations included in the lease itself, plaintiff fails to show defendant has superior knowledge about who made them.  Plaintiff has a copy of the lease and should know who signed it on defendant’s behalf. 

As for any misrepresentations not made in the lease itself, plaintiff does not allege how or when those representations were made.  In contrast, in West the plaintiff alleged a bank made misrepresentations in two documents that were attached to the complaint and in two phone calls on specific dates.  (West, supra, 214 Cal.App.4th at p. 793.)  The court reasoned, “The identification of the Chase Bank employees who spoke with West on those dates is or should be within Chase Bank’s knowledge.”  (Id. at p. 794.)  Here, plaintiff does not allege details sufficient to permit defendant to identify the individual responsible.  Without more specific details of when and by what means defendant made any misrepresentations, the court cannot conclude defendant has superior knowledge about who acted on its behalf.

Disposition  

Defendant Trea SH Brockman, LLC’s demurrer to plaintiff BHFC Operating, LLC, dba Bottega Louie’s second cause of action is overruled.  Defendant’s demurrers to plaintiff’s third and fourth causes of action are sustained with 20 days’ leave to amend.