Judge: Christopher K. Lui, Case: 24STCV24655, Date: 2025-01-22 Tentative Ruling

Case Number: 24STCV24655    Hearing Date: January 22, 2025    Dept: 76

The following tentative ruling is issued pursuant to Rule of Court 3.1308 at 2:57 PM on January 21, 2025. 

Notice of intent to appear is REQUIRED pursuant to California Rule of Court 3.1308(a)(1).  The Court does not desire oral argument on the motion addressed herein. 

As required by Rule 3.1308(a)(1), any party seeking oral argument must notify ALL OTHER PARTIES and the staff of Department 76 by 4:00 p.m. on January 21, 2025.

Notice to Department 76 may be sent by email to smcdept76@lacourt.org or telephonically at 213-830-0776.

Per Rule of Court 3.1308, the Court may not entertain oral argument if notice of intention to appear is not given.


            Plaintiff tenant alleges that Defendant rented a room to Plaintiff without obtaining a certificate of occupancy.

Defendant Yolanda Arana demurs to the Complaint and moves to strike portions thereof.

TENTATIVE RULING

Defendant Yolanda Arana’s demurrer to the Complaint is SUSTAINED with leave to amend as to the first, second, third, fourth, eighth, ninth, tenth, eleventh and twelfth causes of action and OVERRULED as to the sixth cause of action. 

Defendant’s motion to strike is MOOT as to Paragraph no. 20 of  the First Cause of Action, paragraph no. 31 and the phrase and exemplary damages” in paragraph no. 30 of the Third Cause of Action, paragraph no. 56 of the Eighth Cause of Action, paragraph no. 67 of the Tenth Cause of Action, paragraph no. 76 of the Twelfth Cause of Action, and paragraph no. 10 of the Prayer; and  ¶¶ 28 and 62.

Defendant’s motion to strike is GRANTED with leave to amend as to the request for attorney fees [Prayer, ¶ 8];

Defendant’s motion to strike is DENIED as to ¶¶ 10, 13, 41 and 48. 

Plaintiff is given 30 days’ leave to amend where specified.

ANALYSIS

Demurrer

Meet and Confer

            The form Declaration of Steven E. Weit reflects that Defendant’s counsel satisfied the meet and confer requirement set forth in Civ. Proc. Code, § 430.41.

 Discussion

Defendant Yolanda Arana demurs to the Complaint as follows:

1.         First Cause of Action (Breach of Implied Warranty of Habitability).

            Defendant argues that this cause of action is not supported by factual allegations, only conclusions.

The elements of such an affirmative claim are the existence of a material defective condition affecting the premises’ habitability, notice to the landlord of the condition within a reasonable time after the tenant’s discovery of the condition, the landlord was given a reasonable time to correct the deficiency, and resulting damages. (Quevedo v. Braga (1977) 72 Cal.App.3d Supp. 1, 7–8 [140 Cal. Rptr. 143] (Quevedo), disapproved on other grounds in Knight, supra, 29 Cal.3d at p. 55, fn. 7; see Friedman et al., supra, ¶ 3:100, p. 3-40.5 (rev. # 1, 2013).)

(Erlach v. Sierra Asset Servicing, LLC (2014) 226 Cal.App.4th 1281, 1297.)

The California Supreme Court has held that because “under contemporary conditions, public policy compels landlords to bear the primary responsibility for maintaining safe, clean and habitable housing in our state,” there is a warranty of habitability implied in residential leases in California. (Green, supra, 10 Cal.3d at p. 627.) In Green, the court explained that “[t]his [*1297]  implied warranty of habitability does not require that a landlord ensure that leased premises are in  perfect, aesthetically pleasing condition, but it does mean that ‘bare living requirements’ must be maintained. In most cases substantial compliance with those applicable building and housing code standards which materially affect health and safety will suffice to meet the landlord’s obligations under the common law implied warranty of habitability we now recognize.” (Id. at p. 637, fns. omitted.) 

(Erlach v. Sierra Asset Servicing, LLC (2014) 226 Cal.App.4th 1281, 1296-97 [bold emphasis added].)

            Here, the Complaint does not allege what conditions were materially defective so as to affect the premises’ habitability, i.e., below bare living requirements or not in compliance with applicable building and housing code standards, and Defendant’s failure to correct such conditions after notice and a reasonable opportunity to do so.

            The demurrer to the first cause of action is SUSTAINED with leave to amend.

2.         Second Cause of Action (Negligence).

            Defendant argues that this cause of action is not supported by factual allegations, only conclusions.

A landlord has a duty to use ordinary care to keep common areas over which control is retained in safe condition, with a duty to reasonably inspect those areas. (Beeston v. Lampasona (1960) 182 Cal.App.2d 519, 522-23; Mora v. Baker Commodities (1989) 210 Cal.App.3d 771, 782.)  Moreover, a landlord may not be charged with responsibility for a defective condition unless the landlord has actual knowledge thereof or it has existed for such a time that the landlord reasonably should have known of its existence in time to make repairs. (Busby v. Silverman (1947) 82 Cal.App.2d 393, 396-97.) If a landlord undertakes to repair a defective condition on the leased premises, then ordinary care must be exercised. (Uccello v. Laudenslayer (1975) 44 Cal.App.3d 504, 511.) The landlord must also use ordinary care to eliminate a dangerous condition where the landlord has actual knowledge of defects which are undisclosed, unknown and non-apparent to the tenant, where a nuisance exists at the time the lease is made or renewed, or where a safety law was violated. (Id.)

Plaintiff simply alleges in a conclusion that Defendants breached their duty of care by failing to take reasonable steps to ensure the safety of Plaintiff and prevent him from being exposed to dangerous conditions. (Complaint, ¶ 22.) The Complaint does not specify the dangerous conditions and Defendants’ actual or constructive knowledge thereof and failure to repair such dangerous condition.

 

The demurrer to the second cause of action is SUSTAINED with leave to amend.

 

3.         Third Cause of Action (Negligent Hiring).

 

            Defendant argues that this cause of action is not supported by factual allegations, only conclusions.

“ In California, an employer can be held liable for negligent hiring if he knows the employee is unfit, or has reason to believe the employee is unfit or fails to use reasonable care to discover the employee’s unfitness before hiring him. [Citations.]” (Evan F. v. Hughson United Methodist Church (1992) 8 Cal. App. 4th 828, 843 [10 Cal. Rptr. 2d 748].) “The theory of negligent hiring here encompasses the particular risk of molestation by an employee with a history of this specific conduct.” (Id. at p. 837.) Furthermore, there can be no liability for negligent supervision “in the absence of knowledge by the principal that the agent or servant was a person who could not be trusted to act properly without being supervised.” (Noble v. Sears, Roebuck & Co. (1973) 33 Cal. App. 3d 654, 664 [109 Cal. Rptr. 269, 73 A.L.R.3d 1164].)

(Juarez v. Boy Scouts of America, Inc. (2000) 81 Cal.App.4th 377, 395.)

 

            Plaintiff alleges:

 

26. Defendants had a duty to hire managers and contractors who were knowledgeable in the area and could address genuine concerns in a reasonable manner and timeframe.

 

27. Defendants failed or refused to properly hire, screen, train, and/or supervise those members of their team to carry out their duties in a manner that was well-trained, orderly, and/or competent. 

 

28. Defendants did not adequately respond to Plaintiff’s concerns.

 

29. As a direct and proximate result of Defendants’ failure to properly hire, screen, train and/or supervise their employees, Plaintiff has been injured as explained more fully above. 

 

(Complaint, ¶¶ 26 – 29.)

 

            Plaintiff does not specify any employees hired by Defendant who caused Plaintiff injuries.

 

            The demurrer to the third cause of action is SUSTAINED with leave to amend.

 

4.         Fourth Cause of Action (Breach of Contract).

 

Defendant argues that a review of the Rental Agreement (attached as Exhibit A to the Complaint) reveals that there is no provision in the agreement requiring a “habitable dwelling” which is the only allegation (paragraph no. 34) regarding breach contained in the fourth cause of action.

 

Defendant also argues that there are no factual allegations regarding damages.

 

To state a cause of action for breach of contract, [plaintiff] must plead the contract, his performance of the contract or excuse for nonperformance, [defendant]’s breach and the resulting damage. ( Lortz v. Connell (1969) 273 Cal.App.2d 286, 290 [78 Cal.Rptr. 6].) Further, the complaint must indicate on its face whether the contract is written, oral, or implied  [*459]  by conduct. ( Code Civ. Proc., § 430.10, subd.  (g).) n4 If the action is based on an alleged breach of a written contract, the terms must be set out verbatim in the body of the complaint or a copy of the written instrument must be attached and incorporated by reference. (Wise v. Southern Pacific Co. (1963) 223 Cal.App.2d 50, 59 [35 Cal.Rptr. 652].)

(Otworth v. Southern Pac. Transportation Co. (1985) 166 Cal.App.3d 452, 458-59.)

 

Facts alleging a breach, like all essential elements of a breach of contract cause of action, must be pleaded with specificity. (See generally 4  [*6]  Witkin, Cal. Procedure (4th ed. 1996) Pleading, § 4495, pp. 585–586; Bentley v. Mountain (1942) 51 Cal.App.2d 95, 98 [124 P.2d 91] [general averments that defendants violated contract insufficient; pleader must allege facts demonstrating breach]; Thompson v. Purdy (1931) 117 Cal.App. 565, 567 [4 P.2d 282] [general averments that defendant failed to perform duties or comply with contract insufficient].)

(Levy v. State Farm Mutual Automobile Ins. Co. (2007) 150 Cal.App.4th 1, 5-6.)

 

The Complaint alleges at ¶ 34 that: “Defendants breached the terms of the residential lease agreement, as set forth herein by, among other things, not providing a habitable dwelling.” Plaintiff does not allege the terms of the contract, nor does Plaintiff specify which contract term was breached in a way which constituted a failure to provide a habitable dwelling.

 

The demurrer to the fifth cause of action is SUSTAINED with leave to amend.

 

5.         Sixth Cause of Action (Nuisance).

 

            Defendant argues that the only factual allegation touching on an interference by defendant Arana with plaintiff s use or enjoyment of his rented room is that defendant allegedly entered the dwelling, without notice, at various times throughout the day, although it is not specified (anywhere in the Complaint) as to whether plaintiff is referring to the house generally or plaintiff’s rented room. Defendant argues that a substantial and unreasonable interference is not pled.


To prevail on an action for private nuisance, a plaintiff must first prove an interference with the plaintiff’s use and enjoyment of his or her property. (San Diego Gas & Electric Co. v. Superior Court (1996) 13 Cal.4th 893, 938 [55 Cal. Rptr. 2d 724, 920 P.2d 669] … .) Second, ‘the invasion of the plaintiff’s interest in the use and enjoyment of the land [must be] substantial, i.e., that it cause[s] the plaintiff to suffer “substantial actual damage.”‘ (Ibid.) Third, ‘“[t]he interference with the protected interest must not only be substantial, but it must also be unreasonable” [citation], i.e., it must be “of such a nature, duration or amount as to constitute unreasonable interference with the use and enjoyment of the land.”‘ (Ibid.; accord, Mendez[(v. Rancho Valencia Resort Partners, LLC] 3 Cal.App.5th [248,] 262–263 [207 Cal. Rptr. 3d 532].)” (Chase v. Wizmann (2021) 71 Cal.App.5th 244, 253 [286 Cal. Rptr. 3d 183].)

 

     (Lynch v. Peter & Associates (2024) 104 Cal.App.5th 1181, 1197.)

 

            Plaintiff alleges at ¶ 43:

 

43. Defendants, by harassing and threatening Plaintiff, and by repeatedly

demanding that Plaintiff vacate, as expressed more fully above, obstructed the free use of the Property, so as to interfere with Plaintiff’s comfortable enjoyment of the Property. 

 

Such conduct would suffice to constitute a nuisance if a jury finds it substantially and unreasonably interfered with Plaintiff’s use and enjoyment of the property. This cause of action is sufficiently pled.

 

            The demurrer to the sixth cause of action is OVERRULED.

 

6.         Eighth Cause of Action (Intentional Infliction of Emotional Distress).

 

            Defendant argues that Plaintiff does not factually allege conduct so extreme as to exceed all bounds of that usually tolerated in civilized society. Nor does Plaintiff factually allege severe or extreme emotional distress.

 

“The elements of the tort of 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) actual and proximate causation of the emotional distress by the defendant’s outrageous conduct. …” Conduct to be outrageous must be so extreme as to exceed all bounds of that usually tolerated in a civilized community.’ [Citation.]” (Citation omitted.) “It is not enough that the conduct be intentional and outrageous. It must be conduct directed at the plaintiff, or occur in the presence of a plaintiff of whom the defendant is aware.” (Ibid.)

 

(Catsouras v. Department of California Highway Patrol (2010) 181 Cal.App.4th 856, 874-75.)

 

            Here, Plaintiff alleges that “Defendants enter the dwelling at all times of day and night without proper 24-hour notice and have state[d] to Ms. Ahmed that “they can do whatever they like” because she is “only renting a room.” (Complaint, ¶ 11.) However, entering a “dwelling” is different from entering the room Plaintiff was renting as her private room. There are insufficient facts pled that Defendant engaged in extreme and outrageous conduct for purposes of this tort.

 

            The demurrer to the eighth cause of action is SUSTAINED with leave to amend.

 

7.         Ninth Cause of Action (Negligent Infliction of Emotional Distress).

 

            Defendant argues that this is not an independent cause of action but is only the tort of negligence with emotional distress damages being sought, so this cause of action fails for the same reason that the negligence cause of action fails.

[B]ecause the [*156]  only injury Wilson claimed in her lawsuit was emotional distress, she was required to show that Edison’s breach threatened physical injury to her. (See Potter v. Firestone Tire & Rubber Co. (1993) 6 Cal.4th 965, 984–985 [25 Cal. Rptr. 2d 550, 863 P.2d 795] (Potter) [“[T]here is no independent tort of negligent infliction of emotional distress. [Citation.] The tort is negligence, a cause of action in which a duty to the plaintiff is an essential element. [Citations.] That duty may be imposed by law, be assumed by the defendant, or exist by virtue of a special relationship.”].)  “[U]nless the defendant has assumed a duty to plaintiff in which the emotional condition of the plaintiff is an object, recovery is available only if the emotional distress arises out of the defendant’s breach of some other legal duty and the emotional distress is proximately caused by that breach of duty. Even then, with rare exceptions, a breach of the duty must threaten physical injury, not simply damage to property or financial interests.” (Potter, supra, 6 Cal.4th at p. 985.)

(Wilson v. Southern California Edison Co. (2015) 234 Cal.App.4th 123, 155-56 [bold emphasis added].)

 

            Here, Plaintiff does not allege that she was threatened with physical injury as a result of Defendant’s breach of a duty owed regarding Plaintiff’s emotional condition.

 

            The demurrer to the ninth cause of action is SUSTAINED with leave to amend.

 

8.         Tenth Cause of Action (Fraudulent Misrepresentation).

 

            Defendant argues that this cause of action is not pled with the requisite specificity.

 

            Defendant also argues that the allege misrepresentation made before execution of the rental agreement on July 7, 2016 is more than eight years before this action was filed on September 23, 3024, and thus, this cause of action is barred by the 3-year statute of limitations set forth in Civ. Proc. Code, § 338(d).

 

            Plaintiff alleges at ¶ 62:

 

62. Defendants misrepresented to Plaintiff that the Property safe for human habitation. This was done in order to take advantage of unsuspecting tenants, and to insulate Defendants from relevant tenant protection laws. 

 

            “To establish a claim for deceit based on intentional misrepresentation, the plaintiff must prove seven essential elements: (1) the defendant represented to the plaintiff that an important fact was true; (2) that representation was false; (3) the defendant knew that the representation was false when the defendant made it, or the defendant made the representation recklessly and without regard for its truth; (4) the defendant intended that the plaintiff rely on the representation; (5) the plaintiff reasonably relied on the representation; (6) the plaintiff was harmed; and (7) the plaintiff’s reliance on the defendant’s representation was a substantial factor in causing that harm to the plaintiff. (Citations omitted.)” (Manderville v. PCG&S Group, Inc. (2007) 146 Cal.App.4th 1486, 1498 [italics omitted].)

 

Fraud must be pleaded with specificity rather than with “ ‘general and conclusory allegations.’ “ (Small v. Fritz Companies, Inc. (2003) 30 Cal.4th 167, 184 [132 Cal. Rptr. 2d 490, 65 P.3d 1255].)  The specificity requirement means a plaintiff must allege facts showing how, when, where, to whom, and by what means the representations were made, and, in the case of a corporate defendant, the plaintiff must allege the names of the persons who made the representations, their authority to speak on behalf of the corporation, to whom they spoke, what they said or wrote, and when the representation was made. (Lazar v. Superior Court, supra, 12 Cal.4th at p. 645.)

 

We enforce the specificity requirement in consideration of its two purposes. The first purpose is to give notice to the defendant with sufficiently definite charges that the defendant can meet them. (Committee on Children’s Television, Inc. v. General Foods Corp. (1983) 35 Cal.3d 197, 216 [197 Cal. Rptr. 783, 673 P.2d 660].) The second is to permit a court to weed out meritless fraud claims on the basis of the pleadings; thus, “the pleading should be sufficient ‘ “to enable the court to determine whether, on the facts pleaded, there is any foundation, prima facie at least, for the charge of fraud.” ‘ “ (Id. at pp. 216–217.)

 

(West v. JPMorgan Chase Bank, N.A. (2013) 214 Cal.App.4th 780, 793.)

 

            A cause of action for relief on the ground of fraud or mistake is subject to a three-year statute of limitations.  (Code Civ. Proc., § 338(d).  The cause of action in that case is not deemed to have accrued until the discovery, by the aggrieved party, of the facts constituting the fraud or mistake.”(Id.).  However, if the facts pled in the complaint show that discovery occurred outside of the limitations period, the plaintiff must allege the date and manner of such discovery and why the delay in discovery is excused:

 

            Plaintiff must allege exactly what was said to Plaintiff, when and in what manner (orally or in writing), why such representation was known to be false when made, and Plaintiff’s reliance thereon. Moreover, Plaintiff must allege when she discovered that the property was not safe for human habitation. This date is not specified at ¶ 8. This will impact whether the cause of action is barred by the 3-year statute of limitations.

 

            The demurrer to the tenth cause of action is SUSTAINED with leave to amend.

 

9.         Eleventh Cause of Action (Negligent Misrepresentation).

 

Defendant argues that this cause of action is not pled with the requisite specificity.

 

            Defendant also argues that the allege misrepresentation made before execution of the rental agreement on July 7, 2016 is more than eight years before this action was filed on September 23, 3024, and thus, this cause of action is barred by the 3-year statute of limitations set forth in Civ. Proc. Code, § 338(d).

 

The elements of negligent misrepresentation are ‘(1) the misrepresentation of a past or existing material fact, (2) without reasonable ground for believing it to be true, (3) with intent to induce another’s reliance on the fact misrepresented, (4) justifiable reliance on the misrepresentation, and (5) resulting damage.’ (Citation omitted.)” (National Union Fire Ins. Co. of Pittsburgh, PA v. Cambridge Integrated Services Group, Inc. (2009) 171 Cal.App.4th 35, 50.)

 

            The same pleading specificity requirement applicable to fraud applies to pleading negligent misrepresentation. (Cadlo v. Owens-Illinois, Inc., (2004) 125 Cal.App.4th 513, 519.)

 

            The same analysis applies here as with the fraudulent misrepresentation claim, except that Plaintiff must show that the specific representation was made without reasonable basis for believing it to be true, rather than knowledge that it was not true.

 

            The demurrer to the eleventh cause of action is SUSTAINED with leave to amend.

 

10.       Twelfth Cause of Action (Violation of Civil Code 1940.2).

 

            Defendant argues that this cause of action does not specify the unlawful conduct engaged in by Defendant.

 

            Plaintiff does not specify the provision of Civil Code, § 1940.2 which Defendant allegedly violated, nor the manner in which such violation occurred. “[S]tatutory causes of action must be pleaded with particularity.” (Covenant Care, Inc. v. Superior Court (2004) 32 Cal.4th 771, 790.)

 

            The demurrer to the twelfth cause of action is SUSTAINED with leave to amend.

 

Motion To Strike

 

 

Meet and Confer

 

            The form Declaration of Steven E. Weit reflects that Defendant’s counsel satisfied the meet and confer requirement set forth in Civ. Proc. Code, § 435.5.

 

Discussion

 

 

Defendant Yolanda Arana moves to strike the following portions of the Complaint as follows:

 

1. Paragraph no. 20 of  the First Cause of Action, paragraph no. 31 and the phrase and exemplary damages” in paragraph no. 30 of the Third Cause of Action, paragraph no. 56 of the Eighth Cause of Action, paragraph no. 67 of the Tenth Cause of Action, paragraph no. 76 of the Twelfth Cause of Action, and paragraph no. 10 of the Prayer;

 

MOOT given the ruling on the demurrer to these causes of action.

 

2. The request for attorney fees [Prayer, ¶ 8];

 

GRANTED with leave to amend.

 

“[A]s a general rule, attorney fees are not recoverable as costs unless they are authorized by statute or agreement.” (People ex rel. Dept. of Corporations v. Speedee Oil Change Systems, Inc. (2007) 147 Cal.App.4th 424, 429.)

 

Plaintiff must specify a contractual and/or statutory basis for the recovery of attorney’s fees.

 

3. The entirety of paragraph nos. 10, 13, and 28, and portions of paragraph nos. 41, 48, and 62, as irrelevant and improper.

 

DENIED as to ¶¶ 10, 13, 41 and 48. These allegations are relevant and proper.

 

MOOT as to ¶¶ 28 and 62 by virtue of the ruling on the demurrer.

 

Plaintiff is given 30 days’ leave to amend where specified.