Judge: Ashfaq G. Chowdhury, Case: 24GDCV00150, Date: 2025-02-13 Tentative Ruling



Case Number: 24GDCV00150    Hearing Date: February 13, 2025    Dept: E

Case No: 24GDCV00150
Hearing Date: 02/13/2025 – 8:30am

Trial Date: UNSET

Case Name: ATOM PETROSYAN v. INTERINSURANCE EXCHANGE OF THE AUTOMOBILE CLUB; and DOES 1-50, inclusive

 

[TENTATIVE RULING ON DEMURRER & MOTION TO STRIKE]

DEMURRER

 

PROCEDURAL

Moving Party: Defendant, Interinsurance Exchange of the Automobile Club (Defendant or Exchange)

Responding Party: Plaintiff, Atom Petrosyan

Moving Papers: Notice/Demurrer; Colin M. Adkins Declaration

Opposition Papers: Opposition

Reply Papers: Reply

Proof of Service Timely Filed (CRC Rule 3.1300(c)): Ok
16/21 Court Days Lapsed (CCP § 1005(b)): Ok
Proper Address (CCP § 1013, § 1013a, § 1013b): Ok

Meet and Confer
A party filing a demurrer “shall meet and confer in person or by telephone with the party who filed the pleading that is subject to demurrer for the purpose of determining whether an agreement can be reached that would resolve the objections to be raised in the demurrer.”  (Code Civ. Proc., §430.41, subd. (a).)  “The parties shall meet and confer at least five days before the date the responsive pleading is due. If the parties are not able to meet and confer at least five days prior to the date the responsive pleading is due, the demurring party shall be granted an automatic 30-day extension of time within which to file a responsive pleading, by filing and serving, on or before the date on which a demurrer would be due, a declaration stating under penalty of perjury that a good faith attempt to meet and confer was made and explaining the reasons why the parties could not meet and confer.”  (Code Civ. Proc., §430.41, subd. (a)(2).)

Failure to sufficiently meet and confer is not grounds to overrule or sustain a demurrer. (Code Civ. Proc., §430.41(a)(4).)

Here, Defendant’s counsel met and conferred, but an agreement could not be reached. (Adkins Decl. ¶¶ 4-7.)

RELIEF REQUESTED
Defendant, Interinsurance Exchange of the Automobile Club, will and hereby does generally demur to Plaintiff, Atom Petrosyan’s, First Amended Complaint pursuant to CCP § 430.10 on the grounds that: both causes of action fail to state a claim against the Exchange.

BACKGROUND
Plaintiff, Atom Petrosyan, filed the original Complaint on 1/26/2024.

On 11/26/2024, Plaintiff filed a First Amended Complaint (FAC) against Defendant, Interinsurance Exchange of the Automobile Club, alleging two causes of action for: (1) Bad Faith Breach of Implied Covenant of Good Faith and Fair Dealing, and (2) Breach of Contract.

Plaintiff alleges that he operated a 2011 Toyota Yaris (the vehicle) that was insured by Interinsurance Exchange of the Automobile Club with a policy number CAA161868392. (FAC ¶ 9.) Plaintiff alleges he got into a collision wherein the tortfeasor fled the scene, and he could not obtain any identifying information. (Id.) Plaintiff alleges he sustained personal injury and property damage. (Id.)

Plaintiff alleges he submitted his injury claims to the Exchange for payment under the Uninsured Motorist coverage. (FAC ¶ 10.)

Plaintiff alleges that the Exchange breached the insurance policy by failing to properly investigate and pay legitimate claims made by the Plaintiff. (FAC ¶ 29.)

LEGAL STANDARDS FOR DEMURRERS
Demurrer – Sufficiency
A demurrer for sufficiency tests whether the complaint states a cause of action.  (Hahn v. Mirda, (2007) 147 Cal.App.4th 740, 747.)  When considering demurrers, courts read the allegations liberally and in context. (Taylor v. City of Los Angeles Dept. of Water and Power (2006) 144 Cal.App.4th 1216, 1228.) The court “treat[s] the demurrer as admitting all material facts properly pleaded, but not contentions, deductions or conclusions of fact or law ….”  (Berkley v. Dowds (2007) 152 Cal.App.4th 518, 525.) In a demurrer proceeding, the defects must be apparent on the face of the pleading or via proper judicial notice.  (Donabedian v. Mercury Ins. Co. (2004) 116 Cal.App.4th 968, 994.) A demurrer tests the pleadings alone and not the evidence or other extrinsic matters; therefore, it lies only where the defects appear on the face of the pleading or are judicially noticed.  (Code Civ. Proc., §§ 430.30, 430.70.) The only issue involved in a demurrer hearing is whether the complaint, as it stands, unconnected with extraneous matters, states a cause of action. (Hahn, supra, 147 Cal.App.4th at 747.) 

The general rule is that the plaintiff need only allege ultimate facts, not evidentiary facts.  (Doe v. City of Los Angeles (2007) 42 Cal.4th 531, 550.)  “All that is required of a plaintiff, as a matter of pleading … is that his complaint set forth the essential facts of the case with reasonable precision and with sufficient particularity to acquaint the defendant with the nature, source and extent of his cause of action.” (Rannard v. Lockheed Aircraft Corp. (1945) 26 Cal.2d 149, 156-157.) 

On demurrer, a trial court has an independent duty to “determine whether or not the … complaint alleges facts sufficient to state a cause of action under any legal theory.” (Das v. Bank of America, N.A. (2010) 186 Cal.App.4th 727, 734.) Demurrers do not lie as to only parts of causes of action, where some valid claim is alleged but “must dispose of an entire cause of action to be sustained.”  (Poizner v. Fremont General Corp. (2007) 148 Cal.App.4th 97, 119.) “Generally it is an abuse of discretion to sustain a demurrer without leave to amend if there is any reasonable possibility that the defect can be cured by amendment.”  (Goodman v. Kennedy (1976) 18 Cal.3d 335, 349.)

ANALYSIS


First Cause of Action (Bad Faith Breach of the Implied Covenant of Good Faith and Fair Dealing) and Second Cause of Action (Breach of Contract)
Defendant quotes Brizuela v. CalFarm Ins. Co. which states, “An insured’s compliance with a policy requirement to submit to an examination under oath is a prerequisite to the right to receive benefits under the policy.” (Brizuela v. CalFarm Ins. Co. (2004) 116 Cal.App.4th 578, 587.)

Defendant then argues that the first and second causes of action fail to state a claim because the FAC admits that Plaintiff functionally refused to sit for an EUO, a policy condition precedent to payment.

The Court does not find Defendant’s argument availing.

In a demurrer proceeding, the defects must be apparent on the face of the pleading or via proper judicial notice. (Donabedian v. Mercury Ins. Co. (2004) 116 Cal.App.4th 968, 994.) A demurrer tests the pleadings alone and not the evidence or other extrinsic matters; therefore, it lies only where the defects appear on the face of the pleading or are judicially noticed. (Code Civ. Proc., §§ 430.30, 430.70.)

Although Defendant argues that Plaintiff admitted to refusing to sit for an EUO, this argument is unavailing and outside the scope of the instant demurrer hearing. Defendant’s argument relies on Defendant’s subjective interpretation of the alleged facts in the FAC, and the FAC does not explicitly admit that Plaintiff refused to sit for an EUO.

Further, Defendant’s reliance on Brizuela is inapposite. Brizuela was not at the pleading stage; Brizuela is an appeal from the trial court’s entry of summary judgment. The instant hearing is a hearing on a demurrer, not a hearing on a motion for summary judgment.

TENTATIVE RULING DEMURRER
Defendant’s demurrer to the first and second causes of action is OVERRULED. Defendant’s argument relied on matters outside the scope of a hearing on a demurrer. Defendant’s argument relied on Defendant’s subjective interpretation of Plaintiff’s FAC in an attempt to construe the FAC as admitting that Plaintiff refused to sit for an EUO. Defendant relied on the cases of: (1) Brizuela v. CalFarm Ins. Co. (2004) 116 Cal.App.4th 578, (2) Globe Indemnity Co. v. Superior Court (1992) 6 Cal.App.4th 725, and (3) Love v. Fire Ins. Exchange (1990) 221 Cal.App.3d 1136. All three of those cases were not at the pleading stage like the instant case.

 

MOTION TO STRIKE

Moving Party: Defendant, Interinsurance Exchange of the Automobile Club

Responding Party: Plaintiff, Atom Petrosyan

Moving Papers: Notice/Motion to Strike; Colin M. Adkins Declaration

Opposition Papers: Opposition

Reply Papers: Reply

RELIEF REQUESTED
Defendant moves to strike the following allegations of punitive damages from the FAC on the grounds that the pleading fails to state facts sufficient to support an award of such damages pursuant to CCP §§ 435 and 436:

1. Page 9:5-13: “25. In committing the aforementioned acts, AAA acted with oppression fraud, and malice with the intent to willfully injure, harass, vex, and annoy PLAINTIFF with a conscious disregard for its [sic] rights. All of the aforementioned alleged acts were done or ratified by AAA’s management-level employees, who acted with the knowledge that the defendant’s conduct would cause PLAINTIFF harm. PLAINTIFF is, therefore, entitled to recover punitive damages pursuant to California Civil Code Section 3294.”

2. Page 11: 2-3: “6. … For exemplary and punitive damages according to proof and in an amount sufficient to punish the Defendant according to each Defendant’s net worth.”

PROCEDURAL
Meet and Confer
Before filing a motion to strike pursuant to this chapter, the moving party shall meet and confer in person or by telephone with the party who filed the pleading that is subject to the motion to strike for the purpose of determining if an agreement can be reached that resolves the objections to be raised in the motion to strike. If an amended pleading is filed, the responding party shall meet and confer again with the party who filed the amended pleading before filing a motion to strike the amended pleading. (CCP § 435.5(a).)

“A determination by the court that the meet and confer process was insufficient shall not be grounds to grant or deny the motion to strike.” (CCP § 435.5(a)(4).)

Here, Defendant’s counsel met and conferred, but an agreement was not able to be reached. (Adkins Decl. ¶¶ 4-7.)

Legal Standard Motion to Strike
The court may, upon a motion, or at any time in its discretion, and upon terms it deems proper, strike any irrelevant, false, or improper matter inserted in any pleading. (Code Civ. Proc. § 436(a).) The court may also strike all or any part of any pleading not drawn or filed in conformity with the laws of this state, a court rule, or an order of the court. (Code Civ. Proc. § 436(b).) A motion to strike cannot be based upon the grounds that a complaint fails to state facts sufficient to constitute a cause of action, but instead is properly based on grounds of superfluous or abusive allegations, or improprieties in form or procedure. (Ferraro v. Camarlinghi (2008) 161 Cal.App.4th 509, 528-29.)   

The grounds for moving to strike must appear on the face of the pleading or by way of judicial notice. (Code. Civ. Proc. § 437; Turman v. Turning Point of Central California, Inc. (2010) 191 Cal.App.4th 53, 63 [“judges read allegations of a pleading subject to a motion to strike as a whole, all parts in their context, and assume their truth”].)   

Further, CCP § 431.10(a)-(c) states as follows:

(a) A material allegation in a pleading is one essential to the claim or defense and which could not be stricken from the pleading without leaving it insufficient as to that claim or defense.

(b) An immaterial allegation in a pleading is any of the following:

(1) An allegation that is not essential to the statement of a claim or defense.

(2) An allegation that is neither pertinent to nor supported by an otherwise sufficient claim or defense.

(3) A demand for judgment requesting relief not supported by the allegations of the complaint or cross-complaint.

(c) An “immaterial allegation” means “irrelevant matter” as that term is used in Section 436.

 

(CCP § 431.10(a)-(c).)

 

TENTATIVE RULING MOTION TO STRIKE
Plaintiff’s FAC requests punitive damages in ¶ 25 of the FAC. Paragraph twenty five’s request for punitive damages is located within the first cause of action for bad faith breach of the implied covenant of good faith and fair dealing. Additionally, Plaintiff’s Prayer for Relief, with respect to the first cause of action, requests exemplary and punitive damages. Defendant moves to strike both requests on the basis that Plaintiff has not alleged any factual behavior on the part of Defendant that would rise to the level of oppression, fraud, or malice.

In an action for the breach of an obligation not arising from contract, where it is proven by clear and convincing evidence that the defendant has been guilty of oppression, fraud, or malice, the plaintiff, in addition to the actual damages, may recover damages for the sake of example by way of punishing the defendant. (Cal. Civ. Code § 3294(a).)

“‘Malice’ means conduct which is intended by the defendant to cause injury to the plaintiff or despicable conduct which is carried on by the defendant with a willful and conscious disregard of the rights or safety of others.” (CCP § 3294(c)(1).)

“‘Oppression’ means despicable conduct that subjects a person to cruel and unjust hardship in conscious disregard of that person’s rights.” (CCP § 3294(c)(2).)

“‘Fraud’ means an intentional misrepresentation, deceit, or concealment of a material fact known to the defendant with the intention on the part of the defendant of thereby depriving a person of property or legal rights or otherwise causing injury.” (CCP § 3294(c)(3).)

“In order to survive a motion to strike an allegation of punitive damages, the ultimate facts showing an entitlement to such relief must be pled by a plaintiff.”  (Clauson v. Superior Court (1998) 67 Cal. App. 4th 1253, 1255.) Conclusory allegations, devoid of any factual assertions, are insufficient to support a conclusion that parties acted with oppression, fraud or malice. (Smith v. Sup. Ct. (1992) 10 Cal. App. 4th 1033, 1042.) 

Although Defendant argues that Plaintiff has not alleged any factual behavior on the part of Defendant that would give rise to the level of oppression, fraud, or malice, the Court does not find Defendant’s argument availing. Plaintiff has alleged facts that a jury could potentially find rises to the level of oppression, fraud, or malice for Plaintiff’s cause of action for bad faith breach of the implied covenant of good faith and fair dealing.

Further, the Court notes that Plaintiff cited to a case in which an award of punitive damages was proper for a defendant breaching its duty to deal reasonably and in good faith with its insured. (See Neal v. Farmers Ins. Exchange (1978) 21 Cal.3d 910, 922-923.)

Because the instant action is at the pleading stage, the Court does not find Defendant’s argument availing.

Defendant’s motion to strike is DENIED.