Judge: Daniel S. Murphy, Case: 24STCV26671, Date: 2025-04-28 Tentative Ruling

Case Number: 24STCV26671    Hearing Date: April 28, 2025    Dept: 32

BACKGROUND

            On October 11, 2024, Plaintiff David Mitch Parks filed this action for breach of contract against Defendants Lux Angeles Studios; Lux Angeles Entertainment; Jared Safier; Lenny Vitulli; Matthew Macur; and Thomas Walton.

            The complaint stems from Plaintiff’s deal with Defendants to leave his role as a managing partner of Lux Angeles Studios, LLC and to sell his ownership interest to the remaining partners. (Compl. ¶ 12.) The parties allegedly entered into a Settlement Agreement wherein Plaintiff relinquished his interest for 11 monthly installments of $5,635.45. (Id., ¶ 14.) Additionally, Defendants promised to purchase or refinance two Ford Transit vans. (Id., ¶ 15.) This action stems from Defendants’ failure to purchase or refinance the vans. (Id., ¶ 17.)

            On April 4, 2025, Defendants filed the instant motion to reclassify the case from unlimited to limited jurisdiction. Plaintiff filed his opposition on April 15, 2025. Defendants filed their reply on April 21, 2025.

LEGAL STANDARD

The jurisdictional minimum for unlimited civil cases is $35,000. (Code Civ. Proc., §§ 85, 86.) A “defendant or cross-defendant may file a motion for reclassification within the time allowed for that party to respond to the initial pleading.” (Id., § 403.040(a).) “The court shall grant the motion and enter an order for reclassification, regardless of any fault or lack of fault, if the case has been classified in an incorrect jurisdictional classification.” (Ibid.)

“A trial court has authority to conduct a pretrial hearing [a Walker hearing] to obtain information about whether the amount of the judgment will require reclassification.” (Stern v. Superior Court (2003) 105 Cal.App.4th 223, 229.) “Under the Walker standard, a matter may be

reclassified as a limited civil action ‘when (i) the absence of jurisdiction is apparent before trial from the complaint, petition, or related documents, or (ii) during the course of pretrial litigation, it becomes clear that the matter will ‘necessarily’ result in a verdict below the superior court's jurisdictional amount....’” (Ytuarte v. Superior Court (2005) 129 Cal.App.4th 266, 276.)

DISCUSSION

            Defendants contend that the case should be reclassified because Plaintiff served evasive discovery responses or produced inadequate documents that do not demonstrate damages exceeding $35,000. However, this does not demonstrate “to a legal certainty” that Plaintiff cannot recover more than $35,000. (See Ytuarte, supra, 129 Cal.App.4th at p. 277.) “This standard of ‘legal certainty’ is not met when it appears a verdict within the unlimited court's jurisdiction is ‘possible.’” (Ibid.)

            An unsatisfactory discovery response does not render a verdict within the jurisdictional amount impossible. None of the allegations in the complaint nor the cited discovery responses contains any facts showing that the amount is “necessarily” below $35,000. (See Ytuarte, supra, 129 Cal.App.4th at p. 276.) The remedy for a defective discovery response is a motion to compel, not a motion for reclassification. Moreover, Plaintiff produced supplemental responses detailing damages exceeding $35,000. (Andino Decl. ¶ 17, Ex. H.)  

Plaintiff is not required to prove his damages in order to remain in this Court. The Walker standard “involves an evaluation of the amount fairly in controversy, not an adjudication of the merits of the claim.” (Ytuarte, supra, 129 Cal.App.4th at p. 277.) Based on the record currently before the Court, it may be fairly stated that the amount in controversy exceeds $35,000. Therefore, reclassification is not warranted.  

CONCLUSION

            Defendants’ motion for reclassification is DENIED.