Judge: Daniel M. Crowley, Case: 21STCV13675, Date: 2022-12-09 Tentative Ruling

Case Number: 21STCV13675    Hearing Date: December 9, 2022    Dept: 28

Defendant Angel Rosales’s Motion for Summary Judgment

Having considered the moving, opposing and reply papers, the Court rules as follows. 

BACKGROUND

On April 9, 2021, Plaintiffs Antonio Gonzalez (“Gonzalez”), Rodner Gonzalez-Gonzalez (“Rodner”) and Santa Gonzalez-Gonzalez (“Santa”) filed this action against Defendants Oscar Mendez-Luiz (“Mendez”) and Angel Rosales (“Rosales”) for motor vehicle negligence, wrongful death and survival action sounding in negligence. Gonzlez was later dismissed as a Plaintiff. Plaintiffs later amended the complaint to include Defendants Hayk Arakelyan (“Arakelyan”), Uber Technologies, Inc. (“Uber”), Rasier-CA, LLC (“Rasier”) and Anna Saghatelyan (“Saghatelyan”). 

On January 3, 2022, Mendez filed an answer. On August 17, 2022, Mendez-Luiz filed a Cross-Complaint against Cross-Defendants Uber and Rasier for comparative indemnity, contribution and declaratory relief. 

On April 29, 2022, Uber and Rasier filed an answer. On July 18, 2022, Uber and Raiser field a Cross-Complaint against Cross-Defendant Mendez for implied indemnity, contribution and declaratory relief. On August 17, 2022, Mendez filed an answer. 

On June 9, 2022, Arakelyan filed an answer. On September 14, 2022, Saghatelyan filed an answer. 

On August 12, 2022, Rosales filed a Motion for Summary Judgment to be heard on October 26, 2022. The Court continued the hearing to December 9, 2022. On September 22, 2022, Uber and Rasier filed a Joinder to Rosales’s Motion for Summary Judgment. On November 23, 2022, Plaintiffs filed an opposition. On December 2, 2022, Rosales filed a reply.

Trial is currently set for February 3, 2023.

 

PARTY’S REQUESTS

Rosales requests the Court grant summary judgment on the basis that there is no dispute as to material facts. Uber and Rasier join with this request.

Plaintiffs request the Court deny the motion.

 

OBJECTIONS

Plaintiff’s Objections are SUSTAINED.

Uber/Rasier’s Objections are SUSTAINED.

 

LEGAL STANDARD

The function of a motion for summary judgment or adjudication is to allow a determination as to whether an opposing party cannot show evidentiary support for a pleading or claim and to enable an order of summary dismissal without the need for trial. (Aguilar v. Atlantic Richfield Co. (2001) 25 Cal.4th 826, 843.) CCP § 437c(c) “requires the trial judge to grant summary judgment if all the evidence submitted, and ‘all inferences reasonably deducible from the evidence’ and uncontradicted by other inferences or evidence, show that there is no triable issue as to any material fact and that the moving party is entitled to judgment as a matter of law.”  (Adler v. Manor Healthcare Corp. (1992) 7 Cal.App.4th 1110, 1119.)  “The function of the pleadings in a motion for summary judgment is to delimit the scope of the issues; the function of the affidavits or declarations is to disclose whether there is any triable issue of fact within the issues delimited by the pleadings.”  (Juge v. County of Sacramento (1993) 12 Cal.App.4th 59, 67, citing FPI Development, Inc. v. Nakashima (1991) 231 Cal. App. 3d 367, 381-382.)

As to each claim as framed by the complaint, the defendant moving for summary judgment must satisfy the initial burden of proof by presenting facts to negate an essential element, or to establish a defense. (CCP § 437c(p)(2); Scalf v. D. B. Log Homes, Inc. (2005) 128 Cal.App.4th 1510, 1520) Courts “liberally construe the evidence in support of the party opposing summary judgment and resolve doubts concerning the evidence in favor of that party.”  (Dore v. Arnold Worldwide, Inc. (2006) 39 Cal.4th 384, 389.) 

Once the defendant has met that burden, the burden shifts to the plaintiff to show that a triable issue of one or more material facts exists as to that cause of action or a defense thereto. To establish a triable issue of material fact, the party opposing the motion must produce substantial responsive evidence. (Sangster v. Paetkau (1998) 68 Cal.App.4th 151, 166.)

The elements of a cause of action for negligence are well established. They are: (1) a legal duty to use due care; (2) a breach of such legal duty; [and] (3) the breach as the proximate or legal cause of the resulting injury. Ladd v. County of San Mateo, 12 Cal.4th 913, 917 (1996). Negligence per se depends on the violation of a specific duty imposed by statute. Steinle v. City and County of San Francisco, 230 F.Supp.3d 994 (2017). Where a standard of conduct of a reasonable person is expressly defined by legislative enactment or judicial decision, the failure to conform to that standard is negligence per se. Law v. Shoate, 178 Cal.App.2d 739 (1960); Lotta v. City of Oakland, 67 Cal.App.2d 411 (1994). Negligence per se is simply a codified evidentiary doctrine, and thus, the doctrine of negligence per se does not establish tort liability. Beaver v. Tarsadia Hotels, 29 F.Supp.3d 1294 (2014). Under the negligence per se doctrine of California law, violation of a statute gives rise to a presumption of negligence in the absence of justification or excuse. Coppola v. Smith, 935 F.Supp.2d 993 (2013).

A claim for negligence per se requires showing that: (1) defendant violated a statute, ordinance, or regulation; (2) the violation proximately caused injury; (3) the injury resulted from an occurrence the enactment was designed to prevent; and (4) the plaintiff was a member of the class of persons the statute was intended to protect. Safari Club International v. Rudolph, 862 F.3d 1113 (2017); Coppola v. Smith, 935 F.Supp.2d 993 (2013); Vollaro v. Lispi, 224 Cal.App.4th 93 (2014); Spriesterbach v. Holland, 215 Cal.App.4th 255 (2013).

 

DISCUSSION

Plaintiffs allege that Mendez negligently failed to stop at an intersection, resulting in an accident that caused damage to Decedent. Immediately prior to the accident, Mendez alleges he was threatened with a gun by the driver of a black SUV. (UMF 3.) He claims that he ran through the stop sign at the subject intersection in fear for his life. (UMF 5.) Rosales, who was working as an Uber driver, was driving a vehicle through the subject intersection and claims to have had the right of way at the time of the incident; there were no stop signs or traffic lights on the street he was traveling on. (UMF 6-7, 26.) Mendez collided with Rosales at the subject intersection, causing Mendez’s vehicle to spin and swerve towards pedestrian Decedent and Rodner. (UMF 26, 34-35.) Mendez’s vehicle collided with Decedent and Rodner, resulting in injuries that eventually led to Decedent’s death. (UMF 35, 42-45.)

 Plaintiffs allege that Rosales was negligent per se, as he was speeding when the subject incident occurred. The speed limit of the area around the subject intersection is 25 mph. (UMF 12-13.) Rosales claims he was not speeding nor driving recklessly at the time of the incident; he specifically states he was driving at a rate of 24.9 mph just 4.8 seconds prior to the collision. (UMF 28-29.) According to the crash report, his speed never exceeded 25 mph prior to the accident; he was only traveling 18 mph immediately prior to the crash (Ex. N.) Rosales was not intoxicated at the time of the incident. (UMF 16.)

In order to successfully bring a cause of action based in negligence, whether that be negligence per se, general negligence, or motor vehicle negligence, a party must have evidence of duty, breach of duty, causation and damages. Here, the evidence, if given proper foundation, might demonstrate that there is no breach of duty. However, as identified in Plaintiffs’ opposition, there is no foundation provided for the crash data. There is no timely declaration attesting as to how the data was procured or the accuracy of said data. It is merely provided without explanation. Although Rosales later served and filed a declaration from an expert providing some background into the issue, this was not filed with the Court until November 17, 2022. All moving papers for a Motion for Summary Judgment must be served and filed at least 75 calendar days prior to the hearing on the motion in order to give Plaintiff the proper time to review and reply to the information. (CCP § 473c(a)). This is mandatory, not directive. The Court cannot consider an expert declaration submitted less than 30 days prior to the hearing. Therefore, Rosales has failed to provide adequate foundation for his evidence. The only other piece of relevant evidence is Rosales’ own declaration, in which he states he was traveling at least 10 mph over the speed limit at the time of the incident. The Court denies the motion.

 

CONCLUSION

Defendant Angel Rosales’s Motion for Summary Judgment is DENIED.

            Moving party is ordered to give notice of this ruling.

Moving Party is ordered to file the proof of service of this ruling with the Court within five days.

The parties are directed to the header of this tentative ruling for further instructions