Judge: Cherol J. Nellon, Case: 224STCV05044, Date: 2024-11-17 Tentative Ruling



Case Number: 224STCV05044    Hearing Date: November 17, 2024    Dept: 14

#6

Case Background

This is an action for quiet title, cancellation of instruments, accounting, declaratory relief, intentional misrepresentation, conversion, and intentional interference with expected inheritance. Plaintiff alleges that the subject property located at 400 N. La Brea was purchased by Decedents, Ernst and Menora Hacker, and Plaintiff Adi Hacker as joint tenants. After Menora Hacker passed away, Ernst Hacker married two more times. Defendant Niza Hacker is Ernst’s third wife. Niza and her attorney, Kira Masteller, misrepresented to Ernst that the subject property was part of a trust and induced him to transfer 50% of the property from Plaintiff to himself as trustee of the Ernst Hacker Survivor’s Trust. Ernst recorded a second deed transferring 100% of the property to himself as trustee. These deeds were wild deeds because Plaintiff and Ernst shared the title and Ernst had never transferred his interest in the property to the trust. After Ernst passed, Niza continued to unlawfully collect rental income from the subject property.

On February 26, 2024, Plaintiff Adi Hacker, an individual and trustee of the Adi and Isabel Hacker Family Trust, filed his Complaint against Niza Hacker, individually and as trustee to the Ernst Hacker Survivor’s Trust (Survivor Trust), and Wells Fargo Bank.

On April 4, 2024, Plaintiffs filed a First Amended Complaint.

On August 7, 2024, Defendant Niza Hacker filed this demurrer.

On August 12, 2024, Plaintiff dismissed Wells Fargo Bank from this action.

On October 4, 2024, Plaintiff filed an opposition to the demurrer.

On October 10, 2024, Defendant filed a reply.

Instant Pleading

Defendant demurs to Plaintiff’s FAC.

Decision

The demurrer filed by Defendant Niza Hacker is OVERRULED. Defendant is to file an Answer within 20 days of this order.

Judicial Notice

Defendant requests judicial notice of grant deeds executed by Ernst Hacker transferring title to various properties to the Ernst Hacker Survivor’s Trust. The Court will only take judicial notice of the grant deed attached as Exhibit 9 to the request for judicial notice because it concerns the subject property and is thus the only grant deed relevant to this motion. The request is denied as to the first 8 exhibits.

Discussion

Defendant demurs to the FAC on the grounds that (1) Plaintiff lacks standing to quiet title, (2) Plaintiff’s first through fifth causes of action are time-barred, (3) Plaintiff’s sixth cause of action must be dismissed because money cannot be converted, (4) Plaintiff fails to plead fraud with specificity or certainty, (5) Plaintiff’s cause of action for declaratory relief is incidental to the first cause of action, and (6) Plaintiff failed to plead the seventh cause of action for intentional interference with expected inheritance.

Plaintiff disputes whether this demurrer was filed within 30 days after service of the FAC under Code. Civ. Proc., section 430.40(a). However, the parties stipulated to an extension of time to file a response to the FAC, extending the time to respond to August 9, 2024. The demurrer was timely filed on August 7, 2024.

1.     Plaintiff’s standing to bring a cause of action to quiet title

“A quiet title action is a statutory action that seeks to declare the rights of the parties in realty.” (Civ. Code, section 760.020;¿Western Aggregates, Inc. v. County of Yuba¿(2002) 101 Cal.App.4th 278, 305, 130 Cal.Rptr.2d 436.) “‘“The object of the action is to finally settle and determine, as between the parties, all conflicting claims to the property in controversy, and to decree to each such interest or estate therein as he may be entitled to.”’” (Western Aggregates, supra, at p. 305, 130 Cal.Rptr.2d 436.)

To maintain an action for quiet title, a plaintiff must allege: 

 

“(a) A description of the property that is the subject of the action. In the case of tangible personal property, the description shall include its usual location. In the case of real property, the description shall include both its legal description and its street address or common designation, if any. 

 

(b) The title of the plaintiff as to which a determination under this chapter is sought and the basis of the title. If the title is based upon adverse possession, the complaint shall allege the specific facts constituting the adverse possession. 

 

(c) The adverse claims to the title of the plaintiff against which a determination is sought. 

 

(d) The date as of which the determination is sought. If the determination is sought as of a date other than the date the complaint is filed, the complaint shall include a statement of the reasons why a determination as of that date is sought. 

 

(e) A prayer for the determination of the title of the plaintiff against the adverse claims.” (Code Civ. Proc., section 761.020.) 

Here, Defendant first argues that Plaintiff lacks standing to quiet title because Ernst severed his joint tenancy with Plaintiff by executing a grant deed conveying the subject property to himself as trustee of the Survivor Trust.

Civ. Code, section 683.2(a)(1) provides that a joint tenant may sever a joint tenancy in real property as to a joint tenant’s interest without the joinder or consent of the other joint tenants by “execution and delivery of a deed that conveys legal title to the joint tenant's interest to a third person, whether or not pursuant to an agreement that requires the third person to reconvey legal title to the joint tenant.”

Here, the grant deed states Ernst Hacker, as Trustee of the Hacker Family Trust (Family Trust) granted title to the subject property to himself as Trustee of the Survivor Trust. (RJN, Exh. 9.)

The FAC alleges that the transfer was not valid because Plaintiff and Ernst held title as joint tenants at the time of the transfer, not the Family Trust. (FAC ¶20.) The grant deed confirms that Ernst made the transfer in his capacity as trustee of the Family Trust. Ernst, as trustee of the Family Trust, had no right to transfer the subject property. Accepting the facts alleged as true, the grant deed transferring the trust was invalid and failed to convey legal title to a third person. Therefore, the facts alleged show the joint tenancy was not severed, and Plaintiff maintains standing to bring a cause of action to quiet title. The demurrer is OVERRULED on this ground.

2.     Statute of limitations

Defendant next argues that Plaintiff’s first through fifth causes of action are time-barred because the statute of limitations for a quiet title action is 5 years and the subject property was transferred to the Survivor Trust in 2016.

“The Legislature has not established a specific statute of limitations for actions to quiet title.” (Salazar v. Thomas (2015) 236 Cal.App.4th 467, 476, citing Muktarian v. Barmby (1965) 63 Cal.2d 558, 560.) The statute of limitations for the underlying theory of relief controls the applicable period of limitations in quiet title actions. (Id.) “Generally, the most likely time limits for a quiet title action are the five-year limitations period for adverse possession, the four-year limitations period for the cancellation of an instrument, or the three-year limitations period for claims based on fraud and mistake.” (Id.)

Here, Plaintiff asserts causes of action for cancellation of instruments and fraud. Thus, the applicable statute of limitations for the quiet title cause of action is three years or four years. As will be discussed below, the limitations period did not begin to accrue until after Ernst Hacker’s death.

Defendant argues that the applicable statute of limitations is five years under Code Civ. Proc., section 318, which governs actions for recovery of real property. However, a plaintiff remains possessed of land through their own occupancy or the occupancy of their tenants. (Salazar, supra, 236 Cal.App.4th at p.479.) Here, Plaintiff was in possession of the property because it was occupied by his tenants. (FAC ¶25.) Therefore, this is not an action for recovery of real property.

The next issue is when the cause of action for quiet title began to accrue.

In general, a statute of limitations for a quiet title action does not run against one in possession land. (Salazar, supra, 236 Cal.App.4th at p. 477.) A statute of limitations does not run against one in possession of the property even if the plaintiff is aware of a potential adverse claim. (Reuter v. Macal (2020) 57 Cal.App.5th 571, 578 (Reuter).)

“An outstanding adverse claim, which amounts only to a cloud upon the title, is a continuing cause of action, and is not barred by lapse of time, until the hostile claim is asserted in some manner to jeopardize the superior title…Each day’s assertion of such adverse claim gives a renewed cause of action to quiet title until such action is brought.” (Salazar, supra, 236 Cal.App.4th 467 at p. 476, quoting Secret Valley Land Co. v. Perry (1921) 187 Cal. 420, 426-427.) 

Reuter is instructive here. In Reuter, a plaintiff conveyed a joint interest in a condominium to his romantic partner. (Reuter, supra, 57 Cal.App.5th at pp.573-574.) After the relationship ended, the plaintiff filed an action to quiet title. (Id.) The court in Reuter found that although the plaintiff knew about the defendant’s adverse interest in the property, there was no reason for the plaintiff to incur the expense or inconvenience of litigation because the defendant never asserted the adverse claim of title against him. (Id. at p.578.) The statute of limitations could not have begun to run against him while he was in undisturbed possession of the condominium. (Id.)

Here, the statute of limitations has not begun to accrue because Ernst did not assert the adverse claim of title against him. It was not until after Ernst died in August 2021 that Niza refused to relinquish possession and control of rental income from the subject property. (FAC ¶¶24, 25.) It is reasonable to infer that Niza asserted the adverse claim of title against Plaintiff because Niza exercised her claim of title to obtain the rental income generated by the subject property. Therefore, the limitations period did not accrue until sometime after August 2021.

Defendant argues that the cause of action for fraud is time-barred because the alleged misrepresentation Defendant made took place around 2016 when Defendant misrepresented to Ernst that the subject property was part of the Family Trust. (FAC ¶20.) Defendant argues that Plaintiff should have known of the alleged fraud by 2018 at the latest when a second deed was recorded. However, the FAC does not state Plaintiff knew of the misrepresentations when they were made in 2016 or in 2018 when the second deed was recorded. Likewise, there are no facts that Plaintiff should have known that a second deed had been recorded or that the transfer was induced through fraud. It is reasonable to infer that Plaintiff should have known of the fraud in August 2021, when Niza obtained the subject property’s rental income, because Plaintiff would have discovered the circumstances surrounding the transfer. Therefore, the facts pled show Plaintiff discovered the alleged fraud around August 2021.

This action was filed in February 2024, well within the 3-year or 4-year limitations period for the quiet title cause of action and the cause of action for fraud. Therefore, Plaintiff’s claims are not time-barred. Defendant’s demurrer is OVERRULED on this ground.

3.     Conversion

Defendant next argues that the sixth cause of action should be dismissed because money cannot be converted.

To plead a cause of action for conversion, one must allege (1) the plaintiff’s ownership or right to possession of personal property; (2) defendant’s disposition of the property inconsistent with plaintiff’s rights; and (3) resulting damages. (Fremont Indemnity Co. v. Fremont General Corp. (2007) 148 Cal.App.4th 97, 119.)  

 

“‘Conversion is any act of dominion wrongfully exerted over another’s personal property in denial of or inconsistent with his rights therein.’” (Enterprise Leasing Corp. v. Shugart Corp. (1991) 231 Cal.App.3d 737, 747 (quoting Messerall v. Fulwider (1988) 199 Cal.App.3d 1324, 1329).) “‘It is not necessary that there be a manual taking of the property; it is only necessary to show an assumption of control or ownership over the property, or that the alleged converter has applied the property to his own use.’” (Id.) 

Here, Defendant, citing PCO, Inc. v. Christensen, Miller, Fink, Jacobs, Glaser, Weil & Shaprio, LLP (2007) 150 Cal. App. 4th 384, 395, argue that a generalized claim for money is not actionable as conversion. “While it is true that money cannot be the subject of an action for conversion unless a specific sum capable of identification is involved…it is not necessary that each coin or bill be earmarked.” (PCO, Inc., supra, 150 Cal. App. 4th at p. 397, quoting Haigler v. Donnelly (1941) 18 Cal.2d 674, 681.) PCO, Inc. does not stand to bar all causes of action for conversion of money. Rather, a claim for conversion must concern a specific sum, rather than a generalized claim for money.

Here, the FAC states Defendant converted “the rental income from the subject property, which represents a specific sum, identifiable and capable of ascertainment.” (FAC ¶25.) The total rental income which Niza claimed after she refused to allow Plaintiff to collect the money is a specific sum capable of identification. Therefore, Plaintiff may bring a cause of action for conversion as to the rental income. The demurrer is OVERRULED on this ground.

4.     Fraud

Defendant next argues that the cause of action for fraud lacks specificity and is uncertain.

A claim for fraud must plead all the following elements: (1) misrepresentation; (2) knowledge of falsity; (3) intent to induce reliance; (4) justifiable reliance; and (5) resulting damage. (Odorizzi v. Bloomfield School Dist. (1966) 246 Cal.App.2d 123, 128; Wilhelm v. Pray, Price, Williams & Russell (1986) 186 Cal.App.3d 1324, 1332.)   

Fraud causes of actions must be pled with specificity in order to give notice to the defendant and to furnish him or her with definite charges. (Committee on Children's Television, Inc. v. General Foods Corp. (1983) 35 Cal. 3d 197, 216, superseded by amendments to the Unfair Competition Law contained in Proposition 64 on unrelated grounds.)  “(a) General pleading of the legal conclusion of ‘fraud’ is insufficient; the facts constituting the fraud must be alleged.  (b) Every element of the cause of action for fraud must be alleged in the proper manner (i.e., factually and specifically), and the policy of liberal construction of the pleadings … will not ordinarily be invoked to sustain a pleading defective in any material respect.” (Ibid.)  

The specificity standard is less stringent “when ‘it appears from the nature of the allegations that the defendant must necessarily possess full information concerning the facts of the controversy.’” (Committee on Children’s Television, Inc. v. General Foods Corp. (1983) 35 Cal.3d 197, 217, superseded by statute on other grounds as stated in Californians for Disability Rights v. Mervyn's, LLC (2006) 39 Cal.4th 223, 227, quoting Bradley v. Hartford Acc. & Indem. Co. (1973) 30 Cal.App.3d 818, 825.)

Here, Defendant argues that the FAC fails to state how the alleged misrepresentations were made to Ernst. Defendant also argues that the misrepresentations could not have been fraudulent because the alleged fraud took place after Ernst had already transferred the subject property.

The FAC alleges that Niza represented to Plaintiff through her counsel that the subject property had been transferred to the Survivor Trust and that Plaintiff had no interest in the property. (FAC ¶57.) Niza knew the representation was false and continued to demand 50% of the rental income. (FAC ¶58.) Plaintiff reasonably relied on these misrepresentations and could not borrow against, sell, or upgrade the property. (FAC ¶59.)

Contrary to Defendant’s arguments, Plaintiff does not allege the representations made to Ernst were fraudulent, but that the representations made to Plaintiff were fraudulent. The FAC states what misrepresentations were made, to whom they were made, and who made them. Although the FAC lacks some details such as when or how Defendant made the misrepresentations, Defendant necessarily possesses full information about the misrepresentations because she made the misrepresentations. Thus, the specificity standard is relaxed. Because the FAC sufficiently apprises Defendant of the conduct Plaintiff alleges was fraudulent, the Court finds the FAC pleads a cause of action for fraud with sufficient specificity. The demurrer is OVERRULED as to this cause of action.

5.     Declaratory relief

Defendant next demurs to the cause of action for declaratory relief.

A demurrer is generally not an appropriate means to test the merits of a declaratory relief action unless the issues are solely ones of law. (Arroyo v. Regents of University of California (1975) 48 Cal.App.3d 793, 797.) “A demurrer is not the appropriate vehicle to challenge a portion of a cause of action demanding an improper remedy.” (Caliber Bodyworks, Inc. v. Superior Court (2005) 134 Cal.App.4th 365, 384-85; see PH II, Inc. v. Superior Court (1995) 33 Cal.App.4th 1680, 1682-83.) “The appropriate procedural device for challenging a portion of a cause of action seeking an improper remedy is a motion to strike.” (Caliber Bodyworks, Inc., supra, 134 Cal.App.4th at 385.) 

Here, a cause of action for declaratory relief cannot be challenged via a demurrer. Defendant did not move to strike this cause of action. Therefore, the demurrer is OVERRULED as to this cause of action.

6.     Intentional interference with expected inheritance

Defendant finally argues that the FAC does not plead a cause of action for Intentional Interference with Expected Inheritance (IIEI). Defendant argues that (1) Plaintiff failed to plead causation or an independently tortious means and (2) Plaintiff failed to demonstrate that he does not have an adequate remedy in probate court.

The tort of intentional interference with expected inheritance was “developed to provide a remedy when…the plaintiff had no independent tort action because the underlying tort was directed at the testator…[and] the plaintiff had no adequate remedy in probate.” (Beckwith v. Dahl (2012) 205 Cal.App.4th 1039, 1058. (Beckwith).) “To state a claim for [intentional interference with expected inheritance], a plaintiff must allege five distinct elements…First, the plaintiff must plead [s]he had an expectancy of an inheritance…Second, as in other interference torts, the complaint must allege causation…Third, the plaintiff must plead intent, i.e., that the defendant had knowledge of the plaintiff's expectancy of inheritance and took deliberate action to interfere with it…Fourth, the complaint must allege that the interference was conducted by independently tortious means, i.e., the underlying conduct must be wrong for some reason other than the fact of the interference. …Finally, the plaintiff must plead [s]he was damaged by the defendant's interference.” (Id. at p. 1057.)  

A plaintiff may not pursue a remedy in tort, such as IIEI, where a remedy is available in probate to resolve a dispute over the disposition of an estate. (Munn v. Briggs (2010) 185 Cal.App.4th 578, 591.)

Here, as discussed above, Plaintiff’s FAC adequately states a cause of action for fraud. The FAC alleges that Defendant misrepresented to Plaintiff that he had no interest in the subject property. Because the FAC alleges a cause of action for fraud, the FAC alleges Defendant engaged in independent tortious conduct.

Finally, Plaintiff has no probate remedy. Plaintiff expected to have a 100% interest in the subject property as the sole tenant remaining in the joint tenancy. This dispute does not concern the administration of Ernst’s estate because it concerns whether the grant deed transferring the property to the Survivor Trust was valid. If the transfer was invalid, Plaintiff would have had 100% interest in the property. If the transfer was valid, the property would remain in the Survivor Trust. In either scenario, the property is not affected by the administration of Ernst’s estate, leaving Plaintiff with no way to seek a remedy in probate. Therefore, the demurrer to this cause of action is OVERRULED.

Conclusion

The demurrer filed by Defendant Niza Hacker is OVERRULED. Defendant is to file an Answer within 20 days of this order.