Judge: Cherol J. Nellon, Case: 24STCV18304, Date: 2024-11-13 Tentative Ruling

Case Number: 24STCV18304    Hearing Date: November 13, 2024    Dept: 14

#18

Case Background

This is an action for invasion of the right to privacy, violation of Civ. Code, section 3344, intentional infliction of emotional distress, negligence, and violation of Penal Code, section 632.7. Plaintiff alleges that Defendant Ridge illegally recorded a phone conversation about her deceased son without her knowledge. Ridge thereafter videotaped portions of Plaintiff’s son’s funeral without her consent. Thereafter, Ridge posted these recordings on social media.

On July 24, 2024, Plaintiff Judi Paul filed her Complaint against Defendants Patrick Ridge, Danielle Nepus, Madison Mastera, Graceland Ranch, Inc., and Ridge Productions, Inc.

On September 30, 2024, Defendants Patrick Ridge, Danielle Nepus, Madison Mastera, and Graceland Ranch, Inc. (Moving Defendants) filed this motion to strike.

On October 30, 2024, Plaintiff filed an opposition.

On November 5, 2024, Moving Defendants filed a reply.

Instant Pleading

Moving Defendants move to strike portions of Plaintiff’s Complaint.

Decision

Moving Defendants’ motion to strike is DENIED.

Discussion

Moving Defendants move to strike many sections of Plaintiff’s Complaint on the grounds that (1) the language is irrelevant, improper, and inflammatory, and (2) the Complaint contains conclusions of law. Moving Defendants seek to strike many items from the Complaint which generally fall in the following categories:

-        Allegations that Ridge’s conduct was despicable or disgusting

-        Adjectives describing Ridge's conduct as shameless, shocking, disgusting, vile, and other similar words

-        Assertions that the video Ridge took was unauthorized or illegal

-        Quotations taken from the videos Ridge posted on social media

Code Civ. Proc., section 436(a) provides that a court may strike out any irrelevant, false, or improper matter inserted in any pleading.

Whether the language was irrelevant, improper, or inflammatory

Moving Defendants first allege that the allegations of the Complaint contain inflammatory language which is highly prejudicial to Moving Defendants. However, there is no authority which states a Court may strike portions of a pleading for inflammatory or prejudicial content. Moving Defendants’ use of the word “prejudicial” appears to invoke the prejudice standard described in Evid. Code, section 352. However, there is no requirement that a pleading must avoid prejudicing a defendant. A complaint typically describes a defendant’s wrongful conduct which allegedly resulted in some injury to a plaintiff. If a complaint had to avoid prejudicing a defendant, no complaint could survive a motion to strike. Moving Defendants’ argument is thus without merit.

Moving Defendants also argue that the language is irrelevant. Plaintiff’s Complaint includes a cause of action for intentional infliction of emotional distress (IIED).

The elements for a cause of action for intentional infliction of emotional distress are (1) extreme and outrageous conduct by the defendant with the intention of causing, or reckless disregard of the probability of causing, emotional distress; (2) the plaintiff’s suffering severe or extreme emotional distress; and (3) an actual and proximate causal link between the tortious conduct and the emotional distress.¿ (Hughes v. Pair (2009) 46 Cal.4th 1035, 1050.)¿ 

Here, the disputed language describes Ridge’s conduct and characterizes it as shameless, disgusting, and vile, among other descriptors. Because a cause of action for IIED requires that Plaintiff prove Ridge’s conduct was extreme and outrageous, it was not unreasonable to describe Ridge’s conduct using these adjectives. It was also reasonable for Plaintiff to directly quote Ridge’s comments from the content he posted on social media to specifically identify what conduct Plaintiff found extreme and outrageous. Therefore, the disputed language is relevant to Plaintiff’s cause of action for IIED.

Additionally, the alleged inflammatory language is relevant to Plaintiff’s demand for punitive damages.

In order to state a prima facie claim for punitive damages, a complaint must set forth the elements as stated in the general punitive damage statute, Civil Code section 3294. (College Hospital, Inc. v. Superior Court (1994) 8 Cal.4th 704, 721.) These statutory elements include allegations that the defendant has been guilty of oppression, fraud or malice. (Civ. Code, section 3294, subd. (a).) “Malice is defined in the statute as conduct 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.” (College Hospital, Inc., supra, 8 Cal.4th at p. 725 [examining Civ. Code, section 3294, subd. (c)(1)].) “As amended to include [despicable], the statute plainly indicates that absent an intent to injure the plaintiff, ‘malice’ requires more than a ‘willful and conscious’ disregard of the plaintiffs’ interests. The additional component of ‘despicable conduct’ must be found.” (College Hospital, Inc., supra, 8 Cal.4th at p. 725.) 

Here, allegations that Ridge’s conduct was vile, shameless, or disgusting are relevant to whether his conduct was malicious as required under Civ. Code, section 3294 because those descriptors would show Ridge’s conduct rose to the level of despicable conduct required to support a demand for punitive damages. Therefore, the allegations are not irrelevant or improper.

The motion to strike is DENIED on this ground.

Whether the language should be stricken because it includes conclusions of law

Moving Defendants next allege that the language describing Ridge’s conduct as illegal, fraudulent, oppressive, malicious, and outrageous should be stricken because they are legal conclusions. Moving Defendants cite Krug v. Meehan (1952) 109 Cal.App.2d 274, 276 and argue that conclusions of law must be stricken because they are deemed to be surplusage that must be disregarded in considering the sufficiency of a pleading.

Here, as Plaintiff points out, Moving Defendants do not challenge the sufficiency of the Complaint, but move to strike the allegations that constitute legal conclusions. There is no authority to support the assertion that legal conclusions are irrelevant or improper. Rather, as the Krug court held, legal conclusions alone are insufficient to support a cause of action without supporting ultimate facts. The Krug court even notes that “if substantial facts which constitute a cause of action are averred in the complaint or can be inferred by reasonable intendment from the matters which are pleaded, although the allegations of these facts are intermingled with conclusions of law, the complaint is not subject to demurrer for insufficiency.” (Krug, supra, 109 Cal.App.2d at p.277.) In other words, a complaint may survive demurrer even if it contains conclusions of law if the ultimate facts may be inferred from the matters pleaded. Thus, there is no prohibition on legal conclusions in a complaint. Therefore, here, the legal conclusions in Plaintiff’s Complaint are not irrelevant or improper.

Moving Defendants’ motion to strike is DENIED on this ground.

Conclusion

Moving Defendants’ motion to strike is DENIED.