Judge: Bruce G. Iwasaki, Case: 23STCV04425, Date: 2023-10-24 Tentative Ruling

Case Number: 23STCV04425    Hearing Date: October 24, 2023    Dept: 58

 

Judge Bruce G. Iwasaki

Department 58


Hearing Date:             October 24, 2023

Case Name:                Shnayder, et al v. Western Fertility Institute, LLC

Case No.:                    23STCV04425

Matter:                        (1.) Demurrer

(2.) Motion to Strike  

Moving Party:             (1.) Defendant Western Fertility Institute LLC and Ashim Kumar

(2.) Defendants Western Fertility Institute LLC and Ashim Kumar

Responding Party:      (1.) Plaintiffs Olga Shnayder and Mehmet Dogru

                                    (2.) Plaintiffs Olga Shnayder and Mehmet Dogru


Tentative Ruling:      The Demurrer to the First Amended Complaint is sustained without leave as to the first and second causes of action as to Defendant Kumar only, overruled as to the third and fourth causes of action, and sustained with leave as to the fifth cause of action. The Motion to Strike is granted with leave to amend.          


 

            On February 28, 2022, Plaintiffs Olga Shnayder and Mehmet Dogru (Plaintiffs) sued Defendants Western Fertility Institute LLC (Western Fertility) and Ashim Kumar (Kumar) (jointly, Defendants) for various contractual breaches and related tort claims arising from Defendants’ provision of in vitro fertilization and surrogacy services.

 

            Plaintiffs allege that, in August 2021, Plaintiffs engaged Defendants for in vitro fertilization (IVF) and surrogacy services. Plaintiffs agreed to pay a total of $165,000 for a “live birth guarantee” and various associated services (e.g., ultrasounds, blood tests, egg retrievals, embryo transfers). Plaintiffs made a down-payment of $45,000 for the fertility treatments.

 

            Plaintiffs allege that Defendants disregarded pre-existing health conditions of Plaintiff Shnayder – the intended embryo recipient – ignored medical tests, overprescribed medication, and otherwise failed to perform under the parties’ contract. As a result, Plaintiffs have incurred more than $30,000 in additional, unnecessary medical costs and Plaintiff Shnayder “continues to experience pain and other symptoms” as result of Defendants’ breaches.

 

            On May 4, 2023, Defendants demurred to Plaintiffs’ Complaint. The Court sustained the demurrer in its entirety.

 

            On July 10, 2023, Plaintiffs filed a First Amended Complaint, alleging causes of action for (1.) breach of contract, (2.) breach of the implied duty of good faith and fair dealing, (3.) money had and received, (4.) declaratory relief, and (5.) intentional infliction of emotional distress.  

 

            Defendants demurred to the entire First Amended Complaint. Defendants also filed a motion to strike. Plaintiffs filed an opposition to both the demurrer and the motion to strike.

 

            The Court sustains without leave to amend the demurrer to the first and second causes of action as to Defendant Kumar only, overrules as to the third and fourth causes of action and sustains with leave as to the fifth cause of action. The motion to strike is granted with leave to amend.  

 

Legal Standard for Demurrers

 

A demurrer is an objection to a pleading, the grounds for which are apparent from either the face of the complaint or a matter of which the court may take judicial notice. (Code Civ. Proc. § 430.30, subd. (a); see also Blank v. Kirwan (1985) 39 Cal.3d 311, 318.) The purpose of a demurrer is to challenge the sufficiency of a pleading “by raising questions of law.” (Postley v. Harvey (1984) 153 Cal.App.3d 280, 286.) “In the construction of a pleading, for the purpose of determining its effect, its allegations must be liberally construed, with a view to substantial justice between the parties.” (Code Civ. Proc. § 452.) 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 applying these standards, the court liberally construes the complaint to determine whether a cause of action has been stated. (Picton v. Anderson Union High School Dist. (1996) 50 Cal.App.4th 726, 733.)

 

Analysis

 

            Defendants demur to each cause of action on the grounds that none of the claims allege facts sufficient to state a claim.

 

First Cause of Action for Breach of Contract

 

            To prevail on a breach of contract cause of action, a plaintiff must prove: (1) the contract; (2) plaintiff's performance or excuse for nonperformance; (3) defendant's breach; and (4) resulting damages to plaintiff. (Careau & Co. v. Security Pacific Business Credit, Inc. (1990) 222 Cal.App.3d 1371, 1388.)

 

            According to the FAC, the contract required Defendants to provide Plaintiffs with IVF/surrogacy services in exchange for payment of $155,000. (FAC ¶ 8.) Specifically, the Contract agreed to perform certain services required to achieve a live birth with a gestational carrier, including a “live birth guarantee,” unlimited egg retrievals, and unlimited embryo transfers; Defendants were required to provide Plaintiffs these services until a live birth is achieved. (FAC ¶ 8.) The Contract states that if a live birth is not achieved, all money paid by Plaintiff must be refunded. (FAC ¶ 8.)

 

            The FAC further alleges that Defendants breached the terms of the Contract by “failing to provide a “live birth guarantee” including unlimited egg retrievals and unlimited embryo transfers,” “[f]ailing to provide approved GC profiles for review within 4-6 weeks of commencement of treatment as required under the Contract,” “[f]ailing to perform ultrasound and blood tests required under the Contract,” and “[f]ailing to refund the monies” that Plaintiffs paid to Defendants under the Contract.” (SAC ¶ 16.)  

 

            On demurrer, Defendants argue that the entire action alleges that the Defendants were negligent in rendering IVF services, and that these allegations cannot support a breach of contract claim. (Dem. 5:3-6 [citing Bellah v. Greenson (1978) 81 Cal. App.3d 614, 625 [“It is settled that an action against a doctor arising out of his negligent treatment of a patient is an action sounding in tort and not one based upon contract.”].) Further, to the extent the contract makes any representations as to results, Defendants argue that they were not sufficiently clear to be actionable on the Contract. (Dem. 5:7-13 [citing Depenbrok v. Kaiser Foundation Health Plan, Inc. (1978) 79 Cal.App.3d 167, 170-171].)

 

            Defendants are correct that a breach of contract claim will be treated as a medical malpractice claim where the basis of the claim is the defendant’s failure to comply with a medical standard of care. However, the breach of contract claim contains other alleged breaches that do not arise out of negligence, which were not addressed by Defendants’ demurrer. (See FAC ¶ 16.) That is, the demurrer only addresses the ‘guaranteed live birth” allegation: “Plaintiffs contend that Defendants are required to provide Plaintiffs with IVF services until a live birth is achieved. There are zero facts providing that Defendants did not agree to provide such a service, or when such denial occurred.” (Dem. 5:14-16.)

 

            However, because Defendants do not address the remaining alleged breaches – such as the allegation that Defendants have not refunded monies paid by Plaintiffs as required under the Contract – the demurrer to this cause of action fails as to Defendant Western Fertility. There are allegations to support a breach of contract even if not all of Plaintiffs’ alleged breaches are actionable.  

 

            However, the demurrer must be sustained as to Defendant Kumar. The FAC alleges that both Defendants entered into the Contract, and that both Defendants breached said contract. (See FAC, ¶¶ 8, 10.) However, this allegation conflicts with the attached Exhibit A, which shows that the Contract only contained a signatory line for the “representative” of Defendant Western Fertility. (FAC, Ex. A.) This exhibit undermines the allegations in the pleadings. (Holland v. Morse Diesel Intern., Inc. (2001) 86 Cal.App.4th 1443, 1447 [“If facts appearing in the exhibits contradict those alleged, the facts in the exhibits take precedence.”].) Thus, Defendant Kumar, in his individual capacity, was not a signatory to the Contract. Only a signatory to a contract may be liable for breach. (Clemens v. American Warranty Corp. (1987) 193 Cal.App.3d 444, 452.)

 

The FAC alleges that “each of the DEFENDANTS was the agent, partner, joint venture, associate and/or employee of one or more of the other defendants and was acting in the course and scope of such agency, partnership, joint venture, association and/or employment . . ..” (FAC ¶ 7.) This alleged agency relationship between the parties does not make Kumar liable for the actions of its principal. That is, “[d]irectors and officers are not personally liable on contracts signed by them for and on behalf of the corporation unless they purport to bind themselves individually.” (United States Liab. Ins. Co. v. Haidinger-Hayes, Inc. (1970) 1 Cal.3d 586, 595.) Based on the foregoing, Plaintiffs have not alleged facts demonstrating that Defendant Kumar was a party to the contract.

 

The demurrer to this cause of is overruled as to Defendant Western Fertility and sustained as to Defendant Kumar without leave to amend.

 

Second Cause of Action for Breach of the Implied Duty of Good Faith and Fair Dealing

 

            Defendant argues that the breach of contract claim and breach of implied duty of good faith and fair dealing claim “rest on the same alleged facts and damages” such that it fails to state a claim. (Dem. 6:4-6.)

 

“The covenant of good faith and fair dealing, implied by law in every contract, exists merely to prevent one contracting party from unfairly frustrating the other party's right to receive the benefits of the agreement actually made.” (Italics omitted.) The covenant thus has no existence independent of its contractual underpinnings, and cannot impose substantive duties or limits on contracting parties beyond those in the specific terms of their agreement. (Guz v. Bechtel National, Inc. (2000) 24 Cal.4th 317, 349-350.)

 

The FAC alleges the following breaches to the implied covenant of good faith and fair dealing: “a. failing to consider Ms. Shnayder’s history of PCOS and overprescribing medications which caused severe Ovarian Hyperstimulation Syndrome OHSS; b. ignoring blood tests and failing to monitor Ms. Shnayder’s medical condition in the face of repeated complaints; c. representing to PLAINTIFFS that Ms. Shnayder’s complaints were normal and that everything was going as planned, while knowing it was not; d. failing to perform necessary diagnostic testing to rule out complications; e. altering Ms. Shnayder’s medical records to conceal DEFENDANTS’ negligence; and f. attempting to induce PLAINTIFFS to sign a general liability waiver in order to release Ms. Shnayder’s embryos to a different facility.” (FAC ¶ 17.)

 

The majority of these “breaches” constitute claims for medical malpractice arising from Defendants’ failure to comply with a certain standard of care. That is, these claims arise from a tortious duty and not from the contract itself.

 

            However, this cause of action alleges Defendants attempted to induce Plaintiffs “to sign a general liability waiver in order to release Ms. Shnayder’s embryos to a different facility” and altered Plaintiffs’ medical records. (FAC ¶¶ 13, 16.) This allegation may support a breach of implied covenant where it may arguably frustrate the purpose of the fertility service contract.

 

To establish a claim for breach of the implied covenant, the plaintiff must show that the defendant “lacked subjective good faith in the validity of its act” or that “the act was intended to and did frustrate the common purpose” of the underlying contract. (Wolf v. Walt Disney Pictures & Television (2008) 162 Cal.App.4th 1107, 1123.)

            Thus, this claim is overruled as to Defendant Western Fertility. However, this claim fails as to Defendant Kumar for the same reasons as the first cause of action:  there can be no breach of an implied duty of good faith and fair dealing when there is no contract between the parties.

 

Third Cause of Action for Money Had and Received

 

            The 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.’” (Allen v. Powell (1967) 248 Cal.App.2d 502, 510.)

 

            The FAC, here, alleges fertility services were sought from Defendants in exchange for money paid by Plaintiffs. However, the service sought were allegedly not provided and Defendants have not returned the funds paid. (FAC ¶¶ 31-36.) The demurrer to this cause of action is overruled.

 

Fourth Cause of Action for Declaratory Relief

 

            The declaratory relief cause of action is largely derivative of the breach of contract claim. (FAC ¶¶ 37-39.)

 

            “Any person interested ... under a contract ... may, in cases of actual controversy relating to the legal rights and duties of the respective parties, bring an original action ... in the superior court for a declaration of his or her rights and duties ... including a determination of any question of construction or validity arising under the ... contract. He or she may ask for a declaration of rights or duties, either alone or with other relief; and the court may make a binding declaration of these rights or duties, whether or not further relief is or could be claimed at the time. The declaration may be either affirmative or negative in form and effect, and the declaration shall have the force of a final judgment. The declaration may be had before there has been any breach of the obligation in respect to which said declaration is sought.” (Code Civ. Proc., § 1060.) “The court may refuse to exercise the power granted by this chapter in any case where its declaration or determination is not necessary or proper at the time under all the circumstances.” (Code Civ. Proc., § 1061.) Sections 1060 and 1061 “must be read together . . ..” (Meyer v. Sprint Spectrum L.P. (2009) 45 Cal.4th 634, 647.)

 

“ ‘[T]he court's decision to grant or deny [declaratory] relief will not be disturbed on appeal unless it be clearly shown ... that the discretion was abused.’ ” (Pellegrini v. Weiss (2008) 165 Cal.App.4th 515, 529.) At the same time, “[t]his discretion is not boundless: ‘Where ... a case is properly before the trial court, under a complaint which is legally sufficient and sets forth facts and circumstances showing that a declaratory adjudication is entirely appropriate, the trial court may not properly refuse to assume jurisdiction....’ ” (Meyer, supra, 45 Cal.4th at p. 647.)

 

“The mere circumstance that another remedy is available is an insufficient ground for refusing declaratory relief, and doubts regarding the propriety of an action for declaratory relief ... generally are resolved in favor of granting relief.” (Filarsky v. Superior Court (2002) 28 Cal.4th 419, 433.)

 

Defendants have properly alleged a cause of action for declaratory relief. The demurrer is overruled.

 

Fifth Cause of Action for Intentional Infliction of Emotional Distress (IIED)

 

            The FAC alleges that Defendant Kumar, acting as individual and officer of Defendant Western Fertility, engaged in “wrongful conduct” “with the intention of interfering with and violating the public policy of the State of California.” (FAC ¶ 41.)

 

            To allege a cause of action for IIED, plaintiff must plead facts showing: (1) outrageous conduct by the defendant with the intention of causing or reckless disregard of the probability of causing emotional distress, (2) severe emotional suffering and (3) actual and proximate causation of emotional distress. (Hughes v. Pair (2009) 46 Cal.4th 1035, 1050.)

 

“Outrageous conduct” is that which exceeds “all bounds tolerated by a decent society” and that “which is especially calculated to cause” emotional distress. (Stoiber v. Honeychuck (1980) 101 Cal.App.3d 903, 921.) Severe emotional suffering is “emotional distress of such substantial quality or enduring quality that no reasonable person in civilized society should be expected to endure it.” (Potter v. Firestone Tire & Rubber Co. (1993) 6 Cal.4th 965, 1004.)

 

            Here, the FAC is vague as to the specific conduct underlying this claim. Moreover, none of the acts alleged in the FAC are sufficiently extreme and outrageous to support this cause of action. The demurrer to this cause of action is sustained with leave to amend.

 

Legal Standard for Motions to Strike

 

            Defendants also move to strike the request for punitive damages in the FAC. Specifically, Defendants move to strike the punitive damages request on the grounds that Plaintiffs have failed to allege fact supporting malice, fraud, or oppression.

 

            “The court may, upon a motion made pursuant to Section 435, or at any time in its discretion, and upon terms it deems proper: (a) Strike out any irrelevant, false, or improper matter inserted in any pleading. (b) Strike out 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.) “Immaterial” or “irrelevant” matters include allegations not essential to the claim, allegations neither pertinent to nor supported by an otherwise sufficient claim or a demand for judgment requesting relief not supported by the allegations of the complaint. (Code Civ. Proc. § 431.10, subds. (b)(1)-(3).)

 

Punitive damages are recoverable where the defendant has been guilty of oppression, fraud, or malice, express or implied. (Civ. Code § 3294.) “Something more than the mere commission of a tort is always required for punitive damages. There must be circumstances of aggravation our outrage, such as spite or malice, or a fraudulent or evil motive on the part of the defendant, or such a conscious and deliberate disregard of the interests of others that his conduct may be called willful or wanton.” (Taylor v. Superior Court (1979) 24 Cal.3d 890, 894.) Specific intent to injure is not necessary for a showing of malice—it is sufficient that the defendant’s conduct was so “wanton or so reckless as to evince malice or conscious disregard of others’ rights.” (McConnell v. Quinn (1925) 71 Cal. App. 671, 682.)

 

A request for punitive damages that is not supported with specific allegations of oppression, fraud, or malice is subject to a motion to strike. Conclusory allegations that defendants acted “willfully,” “maliciously,” or with “oppression, fraud, or malice” are not, without more, sufficient to give rise to a claim for punitive damages, but such language is permissible where the complaint contains sufficient factual support for the conclusions. (Perkins v. Superior Court (1981) 117 Cal.App.3d 1, 6-7.)

 

As a result of the Court sustaining the demurrer to the IIED cause of action, there are no longer any causes of action to support the request for punitive damages. (Purcell v. Schweitzer (2014) 224 Cal.App.4th 969, 976 [“Punitive damages are not recoverable in breach of contract actions.”]; Spinks v. Equity Residential Briarwood Apartments (2009) 171 Cal.App.4th 1004, 1054 [“Since a party “may not recover in tort for ... breach of the implied covenant of good faith and fair dealing,” an “award of punitive damages” is not permitted on such a claim.”].) The motion to strike is granted with leave to amend.

 

Conclusion

 

The demurrer is sustained without leave to amend as to the first and second causes of action as to Defendant Kumar only, and otherwise overruled.  The demurrer is overruled as to the third and fourth causes of action, and sustained with leave to amend as to the fifth cause of action. The motion to strike is granted with leave to amend. The amended complaint shall be served and filed on or before November 27, 2023.