Judge: Armen Tamzarian, Case: 24STCV18825, Date: 2025-02-13 Tentative Ruling

Case Number: 24STCV18825    Hearing Date: February 13, 2025    Dept: 52

Tentative Ruling:

Cross-Defendant Jaeil Lee’s Motion to Strike Strategic Lawsuit Against Public Participation

Cross-defendant Jaeil Lee specially moves to strike numerous portions of the cross-complaint by defendants/cross-complainants AcuProGroup, Inc., Bongchol Yi, and Minhee Chang.

Summary of Pleadings

            Lee’s complaint alleges defendants committed various Labor Code violations (and related causes of action) arising from his employment as an acupuncturist at AcuProGroup. 

The cross-complaint against Lee asserts five causes of action.  Cross-complainants allege Lee was never an employee of AcuProGroup.  They instead allege he volunteered to be an unpaid intern at AcuProGroup.  Cross-complainants further allege Lee was in the United States on a student visa and had no legal permission to work in this country.  Cross-complainants allege AcuProGroup sponsored Lee’s immigration application.  They also allege that in 2024, “Lee fraudulently secured the passwords for [Minhee Chang’s] computer, accessed the confidential patient and insurance financial billing platform for AcuProGroup, Inc. and further accessed the confidential and private patient, insurance, and financial information of the business operations.”  (Cross-Comp., ¶ 18.)  The cross-complaint alleges Lee used Chang’s computer to attempt to “electronically transfer business funds to himself.”  (Ibid.) 

Discussion

Courts use a two-step process for resolving anti-SLAPP motions under Code of Civil Procedure section 425.16: “First, the court decides whether the defendant has made a threshold showing that the challenged cause of action is one arising from protected activity.”  (Navellier v. Sletten (2002) 29 Cal.4th 82, 88 (Navellier).)  The defendant must show “the cause of action is based on the defendant’s protected free speech or petitioning activity.”  (Id. at p. 89.) 

Second, once the defendant establishes the first element, courts “must then determine whether the plaintiff has demonstrated a probability of prevailing on the claim.”  (Navellier, 29 Cal.4th at p. 88.)  “[T]he plaintiff need only have stated and substantiated a legally sufficient claim.”  (Ibid., internal quotes and citations omitted.)  “[C]laims with the requisite minimal merit may proceed.”  (Id. at p. 94.)  “Put another way, the plaintiff ‘must demonstrate that the complaint is both legally sufficient and supported by a sufficient prima facie showing of facts to sustain a favorable judgment if the evidence submitted by the plaintiff is credited.’ ”  (Wilson v. Parker, Covert & Chidester (2002) 28 Cal.4th 811, 821.)

I. Protected Activity

Lee meets his burden of showing that only one of the numerous challenged portions of the cross-complaint constitutes protected activity that supplies an element of the cross-complaint’s causes of action.  Lee contends the specified portions of the cross-complaint are protected activity because they arise from his filing of this lawsuit.  (Motion, p. 4.)  Protected activity includes “any written or oral statement or writing made in connection with an issue under consideration or review by a legislative, executive, or judicial body, or any other official proceeding authorized by law.”  (Code Civ. Proc., § 425.16, subd. (e)(2).)  This provision is “construed broadly, to protect the right of litigants” and applies to a communication “if it has ‘ “some relation” ’ to judicial proceedings.”  (Healy v. Tuscany Hills Landscape & Recreation Corp. (2006) 137 Cal.App.4th 1, 5.)

Most of the challenged portions of the cross-complaint do not constitute protected activity—even without considering whether the cross-complaint seeks to hold Lee liable for that purportedly protected activity.  Instead, the challenged portions allege conduct that preceded Lee’s lawsuit and that was not connected to anticipated litigation.  For example, the first challenged portion of the cross-complaint is the allegation that “Lee did not have proper immigration status or work permit to be gainfully employed in the United States.”  (Cross-Comp., ¶ 2.)  That constitutes a legal conclusion independent of Lee’s lawsuit against defendants.  The second challenged portion is that “Lee confirmed that he only had a student visa and asked Yi to support Lee in his efforts to secure a work permit.”  Again, that preceded this lawsuit and is not petitioning activity.  With four exceptions, the same conclusion applies to all challenged portions of the cross-complaint.

Only the following portions of the cross-complaint constitute protected activity under Code of Civil Procedure section 425.16(e):

(1) “If LEE is alleging that he was an employee despite his specific representations that he knew, understood and agreed that it was unlawful for him to be employed and paid wages under this student visa, then LEE knowingly, intentionally, planned, intended, and specifically strategized to commit felony violations of immigration laws, including but not limited to violations of 18 U.S. Code §1546.”  (Cross-Comp., ¶ 17.) 

(2) “Cross Complainants are informed and believe that LEE is [now] claiming he was an employee, and that he worked 10 hours per day which is impossible since the business operations are only open for 8 hours and the facilities are otherwise locked and closed.”  (¶ 20.)

(3) “[U]pon learning that LEE is now fraudulently claiming that he committed felony violations of immigration laws by claiming he was an employee and entitled to wages while under his student visa…”  (¶ 21.)

(4) Lee was “committing fraud … and falsely claiming that his volunteer internship was … working.”  (¶ 27.)

These four portions of the cross-complaint specifically refer to what Lee is “alleging” or “claiming.”  His complaint in this civil action makes those allegations and claims.  These portions of the cross-complaint therefore constitute protected activity. 

The first three portions above, however, do not supply the elements of the cross-complaint’s causes of action such that cross-complainants seek to hold Lee liable for protected activity.  “ ‘[A] claim is not subject to a motion to strike simply because it contests an action or decision that was arrived at following speech or petitioning activity, or that was thereafter communicated by means of speech or petitioning activity.  Rather, a claim may be struck only if the speech or petitioning activity itself is the wrong complained of, and not just evidence of liability or a step leading to some different act for which liability is asserted.’  [Citation.]  Thus, in evaluating an anti-SLAPP motion, ‘courts should consider the elements of the challenged claim and what actions by [the] defendant supply those elements and consequently form the basis for liability.’ ”  (Golden Gate Land Holdings LLC v. Direct Action Everywhere (2022) 81 Cal.App.5th 82, 90.)  “Courts must be careful to distinguish allegations of conduct on which liability is based from allegations of motives for such conduct.  The court reviews the parties’ pleadings, declarations, and other supporting documents to determine what conduct is actually being challenged, not to determine whether the conduct is actionable.”  (San Diegans for Open Government v. San Diego State University Research Foundation (2017) 13 Cal.App.5th 76, 94.)

Lee’s papers do not identify the elements of the cross-complaint’s causes of action or analyze how the challenged allegations supply those elements.  The first three of the four portions discussed above do not supply the elements of any claims.  Instead, those allegations explain why cross-complainants now believe Lee’s prior representations and conduct were false or fraudulent.  The elements of the claims for fraud, breach of contract, and the other causes of action are supplied by the allegations that Lee falsely told cross-complainants that he would work as an unpaid intern on a student visa and would not be an employee.  Then, when Lee filed his complaint to allege or claim he was actually an employee entitled to wages, that demonstrated his prior conduct—which was not related to his free speech or petitioning activity—was fraudulent. 

The allegations that follow portion (3) above illustrate this: “[U]pon learning that Lee is now fraudulently claiming that he committed felony violations of immigration laws by claiming he was an employee and entitled to wages while under his student visa, AcuProGroup, Inc. instructed [immigration attorney Kisuk] Paek to immediately withdraw, cease, and close AcuProGroup, Inc.’s sponsorship of Lee’s immigration application. Cross Complainants allege that all representations that Lee submitted in his immigration application were false and false were made.”  (Cross-Comp., ¶ 21, italics added.)  The allegedly fraudulent conduct for which cross-complainants seek to hold Lee liable was not that Lee made false statements in his complaint in July 2024.  The alleged fraud is that he made false representations in his immigration application before he filed the lawsuit.  Then cross-complainants learned those prior representations were false when plaintiff filed a civil action contradicting his prior representations.

Some of the fourth portion specified above constituted protected activity that purports to supply the element of breach for the second cause of action for breach of contract.  The cross-complaint alleges, “[A]n oral contract existed between YI, ACCUPROGROUP, INC. on the one hand and LEE on the other hand, wherein LEE was a volunteer, unpaid intern, who was not an employee, and who would be onsite at random times to learn, educate and acquire skills which would solely benefit LEE.”  (¶ 26.)  “In or about July of 2024, LEE breached said agreement by among other things violating patient rights, committing fraud as outlined in the FIRST CAUSE OF ACTION, and falsely claiming that his volunteer internship was a criminal enterprise of working without a work permit which means that LEE’s immigration application knowingly contained fraudulent and false information.”  (¶ 27, challenged portion in italics.) 

“[C]ommitting fraud as outlined in the first cause of action” does not constitute a protected activity because, as discussed above, the alleged fraud is not that Lee makes false claims in his complaint.  As to “falsely claiming that his volunteer internship was … working”, the cross-complaint alleges that false claim itself breached the parties’ oral contract.  Lee meets his burden of showing that portion of the cross-complaint constitutes protected activity that supplies an element of the cause of action for breach of oral contract.

II. Probability of Prevailing

            As to the lone allegation that proceeds to prong two of the anti-SLAPP analysis, cross-complainants show no probability of prevailing on the merits.  The alleged contract is that Lee “was a volunteer, unpaid intern, who was not an employee, and who would be onsite at random times to learn, educate and acquire skills which would solely benefit Lee.”  (Cross-Comp., ¶ 26.)  The protected activity that purportedly constituted breach was “falsely claiming that his volunteer internship was a criminal enterprise of working without a work permit.”  (¶ 27.)  That could not breach the contract alleged because the contract does not prohibit Lee from doing that.  The contract’s terms were that Lee would serve as an unpaid intern.  Allegedly lying about the contract’s terms afterward does not breach any term of the contract. 

Attorney Fees

In his moving papers, Lee seeks attorney fees incurred for this motion.  A party who prevails on an anti-SLAPP motion is entitled to recover attorney fees.  (Code Civ. Proc., § 425.16, subd. (c)(1).)  But a defendant who achieves an “illusory victory” with no practical result is not a prevailing party and cannot recover attorney fees.  (Moran v. Endres (2006) 135 Cal.App.4th 952, 955.) 

Lee’s anti-SLAPP motion challenged 16 portions of the cross-complaint.  He succeeded only in striking part of item 15 specified in his notice of motion: “Paragraph 27 (partial), Page 9, part of Line 5, part of Line 6 (‘. . . committing fraud . . . falsely claiming that his volunteer internship was . . . working.’)”  (Motion, p. iv.)  Of that item, Lee successfully struck only the final eight words.  This victory is illusory.  He did not defeat any entire cause of action.  He defeated only a minimal portion of the second cause of action for breach of oral contract.

First Amended Cross-Complaint

            After Lee filed this motion and after cross-complainants filed their opposition, cross-complainants filed a first amended cross-complaint.  A plaintiff or cross-complainant generally “may not seek to subvert or avoid a ruling on an anti-SLAPP motion by amending the challenged complaint ... in response to the motion.”  (JKC3H8 v. Colton (2013) 221 Cal.App.4th 468, 477-478.)  Cross-complainants did not seek to subvert or avoid the ruling on this anti-SLAPP motion by filing an amended complaint.  They opposed the motion before filing the first amended cross-complaint.  Their opposition did not refer to any proposed future amendments.  The circumstances indicate the first amended cross-complaint was filed in response to Lee’s demurrer, not this anti-SLAPP motion. 

In its discretion, the court may strike the first amended cross-complaint in its entirety, then rule on this motion as if there were no first amended cross-complaint.  But doing so would be inefficient.  Instead, striking the portion of the first amended cross-complaint that corresponds to the subject portion of the initial cross-complaint will fully serve the policy behind the anti-SLAPP statute. 

If there were no first-amended cross-complaint, the court would strike the italicized text in the following portion of the cross-complaint: falsely claiming that his volunteer internship was a criminal enterprise of working without a work permit.”  (Cross-Comp., ¶ 27, page 9, lines 6 to 7.)  The first amended cross-complaint includes the same text: “falsely claiming to outside parties that his volunteer internship was a criminal enterprise of working without a work permit.”  (FACC, ¶ 27, page 12, lines 20 to 21.)  The court will therefore strike that portion of the first amended cross-complaint.

Disposition

Cross-defendant Jaeil Lee’s special motion to strike portions of the cross-complaint is granted in part.  The court hereby strikes the following portion of the first amended cross-complaint without leave to amend: “falsely claiming … that his volunteer internship was … working.”  (First Amended Cross-Comp., ¶ 27, page 12, lines 20 to 21.)