Judge: David A. Rosen, Case: 23GDCV00081, Date: 2023-09-01 Tentative Ruling

Case Number: 23GDCV00081    Hearing Date: September 8, 2023    Dept: E

Case No: 23GDCV00081
Hearing Date: 09/08/2023 – 8:30am

Trial Date: 10/07/2024

Case Name: ROBERTO CARLOS ALVAREZ, an individual v. SUBARU OF AMERICA, INC., a New Jersey Corporation, and DOES 1-10 inclusive

 

I.                   RELIEF REQUESTED

Defendant, Subaru of America, Inc. (SOA or Defendant) moves the Court for an order:

 

(1) Compelling Plaintiff to make his vehicle available for inspection; and

(2) Setting the date of the vehicle inspection.

(3) Imposing monetary sanctions against Plaintiff Roberto Carlos Alvarez and his attorneys, Quill & Arrow, LLP, in the sum of $1,560.00 for Plaintiff’s failure to produce the subject vehicle for inspection and testing, for the failure of counsel to meet and confer in good faith with respect to the production of Plaintiff’s vehicle for inspection and testing, and for the requiring SOA to file this Motion.

 

II.                BACKGROUND

Plaintiff filed a Complaint on 01/17/2023 alleging three causes of action for: (1) Violation of Song-Beverly Act – Breach of Express Warranty, (2) Violation of Song-Beverly Act – Breach of Implied Warranty, and (3) Violation of the Song-Beverly Act Section 1793.2.

The instant action surrounds allegations pertaining to a 2020 Subaru WRX purchased on July 8, 2021. Plaintiff alleges that the Subject Vehicle was delivered to Plaintiff with serious defects and nonconformities to warranty and developed other serious defects and nonconformities to warranty including, but not limited to, engine, electrical, emission, and transmission system defects.

III.             ANALYSIS

Defendant’s counsel argues that several emails were sent to Plaintiff’s counsel requesting dates for a vehicle inspection.

Defendant states that after several emails went unanswered as to setting a date for the vehicle inspection, Defendant served a Demand for Production of Vehicle for Inspection and Testing on April 3, 2023 which was to occur on May 3, 2023.

Defendant states that on April 4, 2023, counsel sent another email to Plaintiff asking if Plaintiff will produce the vehicle, and Plaintiff’s counsel informed Defendant he will not produce the vehicle on May 3, 2023.

Defendant states it made four subsequent attempts to reschedule the inspection and Plaintiff failed to respond to all of Defendant’s emails.

On page 3 of Defendant’s motion in section “III,” Defendant argues:

Code of Civil Procedure section 2031.010, subdivision (c) gives litigants the right not merely to inspect, but also to photograph and test, any tangible thing in another party’s possession, custody, or control. Code of Civil Procedure section 2031.310, subdivision (a) permits a party to file a Motion to compel an inspection.

 

(Def. Mot. p. 3.)

 

Defendant cites 2031.010(c), which states, “A party may demand that any other party produce and permit the party making the demand, or someone acting on the demanding party’s behalf, to inspect and to photograph, test, or sample any tangible things that are in the possession, custody, or control of the party on whom the demand is made.”

 

Defendant also argues that CCP §2031.310(a) permits a party to file a motion to compel an inspection.

 

Either way, it isn’t entirely clear as to the statutory basis for Defendant’s motion as Defendant does not indicate in any clear manner what statutory requirements it is complying with by filing this motion.

 

To add further confusion, Defendant requests sanctions under 2025.450(g)(1) and 2031.310(h). Although 2031.310(h) applies to sanctions with respect to compelling further responses, 2025.450(g)(1) applies to compelling a deposition. Defendant here does not appear to be attempting to compel a deposition; thus, the Court is uncertain as to why Defendant is citing this statute.

 

Generally, it is true that a failure to oppose a motion amounts to a concession on the merits of the motion.  The Court has not been pointed to a reason why the Defendant’s inspection request—which appears reasonable in this case—should not be complied with.

 

IV.             TENTATIVE RULING

Defendant’s motion to compel the vehicle inspection is GRANTED.  Again, the Plaintiff chose not to file an opposition to the request. Though there is some ambiguity as to the statutory basis in which Defendant is moving to compel this inspection, in the Court’s view, the request for inspection appears entirely reasonable in this case.

 

The question of potential sanctions will be addressed at the hearing.