Judge: Elaine W. Mandel, Case: 23SMCV05070, Date: 2024-02-23 Tentative Ruling

Case Number: 23SMCV05070    Hearing Date: March 15, 2024    Dept: P

Tentative Ruling

Scholer, et al. v. Bohrer, et al., Case No. 23SMCV05070

Hearing Date March 15, 2024

Defendants Bohrer/Bohrer Construction, Inc. Demurrer to Complaint

Defendants Mendez Concrete/Mendez Leon’s Demurrer to Complaint & Motion to Strike

 

Homeowner plaintiffs Ryan and Amber Scholer hired general contractor defendants Bohrer and Bohrer Construction, Inc. (BCI) to remodel their property. Plaintiffs allege defendants misrepresented how long the project would take and how much it would cost, causing the project to remain unfinished and go over budget. General contractor defendants demur, as do subcontractor defendants Mendez Master Concrete, Inc. and Eduardo Roberto Mendez Leon (collectively “Mendez”), who also move to strike punitive damages and alter ego allegations.

 

Bohrer/BCI Demurrer

 

Breach of Contract (First CoA)/Disgorgement (Seventh CoA)

On demurrer, facts contained in an exhibit attached to a complaint take precedence over and supersede inconsistent or contrary allegations in the pleading. Jibilian v. Franchise Tax Bd. (2006) 136 Cal.App.4th 862, 864.

 

BCI argues it is not a contracting party; the agreement lists “Ryan and Amber Scholer and Stephen Bohrer” as the parties. Complaint, Exh. A. Plaintiffs point to exhibit B, a mechanic’s lien filed by “Bohrer Construction, a California Corporation” on October 3, 2023. The Scholers argue that by filing this lien, Bohrer admitted BCI was the contractor.

 

The agreement (exh. A) is unambiguous. Under the heading “BETWEEN” it lists “Ryan and Amber Scholer and Stephen Bohrer.” Exh. A, pg. 1. Under the heading “The Contractor,” it names Stephen Bohrer only. Id. There are signature lines for Stephen Bohrer, Ryan Scholer and Amber Scholer only. Id., pg. 2. There is no signature line for BCI. This language is not susceptible to any other interpretation, regardless of the later-filed mechanic’s lien. The language of the exhibit controls over contrary allegations in the complaint. SUSTAINED without leave to amend as to BCI only.

 

Fraud and Negligent Misrepresentation

Under the economic loss rule, conduct amounting to breach of contract cannot give rise to a tort claim unless plaintiff pleads and proves harm above and beyond a broken contractual promise. Robinson Helicopter Co., Inc. v. Dana Corp. (2004) 34 Cal.4th 979, 989. When a contract is fraudulently induced, the economic loss rule does not bar a cause of action for fraud. Id. at 989- 990.

 

Defendants argue the fraud and negligent misrepresentation claims fail because they arise from the agreement and are barred by the economic loss rule. Id. The complaint alleges defendants made material misrepresentations which induced plaintiffs to sign the agreement. Complaint ¶36. The duty to avoid making fraudulent misrepresentations is independent of duties imposed by contract, so not subject to the economic loss rule.

 

Robinson Helicopter, supra, specifically exempts tort claims for fraud from the economic loss rule. Defendants’ interpretation of the rule would effectively abolish the fraudulent inducement cause of action, since all such claims are essentially built upon a breach of contract. OVERRULED.

 

Negligence

The economic loss rule bars negligence claims based on construction defects where there is no showing of property damage or physical injury. McMillin Albany LLC v. Superior Court (2018) 4 Cal.5th 241, 246- 247.

 

Defendants argue this claim is barred by the economic loss rule because no physical injury or property damage is alleged, and no statutory exceptions applies. Plaintiffs argue the negligence claim is not a claim for construction defect, but rather alleges failure to adequately supervise the project so it was completed timely. The project defendants were hired to supervise was a construction project, and the duty plaintiffs allege was breached arose out of a construction contract. Complaint ¶¶50-51. The negligence claim is a construction defect claim, subject to the economic loss rule. SUSTAINED with ten days leave to amend to allege property damage or a statutory exception.

 

Conversion

This cause of action is based on the allegation that Bohrer and BCI “deliberately entered into the Property and removed items that had been installed on the Property, or which were at the Property in anticipation of being installed, all of which Plaintiffs had paid for, and were in the possession of.” Complaint ¶55. Defendants argue the claim is insufficiently pleaded because it does not identify specific items that were allegedly removed. This level of specificity is not required on demurrer. The complaint alleges defendants took plaintiffs’ property. This is sufficient to set forth a cause of action for conversion. OVERRULED.

 

Indemnity

The sixth cause of action for indemnity is alleged against American Contractors Indemnity, not against demurring parties. OVERRULED.

 

Disgorgement

Under Cal. Bus. & Profs. Code §7031(b), “a person who utilizes the services of an unlicensed contractor may bring an action in any court of competent jurisdiction in this state to recover all compensation paid to the unlicensed contractor for performance of any act or contract[.]” For purposes of the statute, “contractor” is “synonymous with builder” and includes work done “himself or herself or by or through others, construct, alter, repair, add to, subtract from, improve, move, wreck or demolish any building, highway, road, parking, railroad, excavation or other structure, project, development or improvement, or to do any part thereof[.]” Cal. Bus. & Profs. Code §7026.

 

BCI argues the same grounds as against the breach of contract claim: it was not a party to the construction agreement. The definition of “contractor” does not require privity of contract. A “contractor” is one who acts as a builder or performs construction, demolition or remodeling work on a structure. Under the facts alleged, BCI meets this definition, regardless of whether it contracted directly with the Scholers.

 

The complaint alleges BCI performed contractor work, Bohrer directed payments be made to BCI, and BCI lacked a contractor’s license. Complaint ¶¶63-64. The allegations– which much be treated as true on demurrer- are that BCI acted as a contractor (though not named in the Agreement) and received payment despite being unlicensed. That BCI did not directly contract with the Scholers is not dispositive on demurrer. OVERRULED.

 

Mendez Demurrer

 

Objection

Mendez defendants object because the opposition filed one day late, on March 5, 2024. Though the opposition was untimely by one day, there is no claimed prejudice; the court will exercise its discretion and consider the opposition.

 

Breach of Contract

Mendez defendants argue plaintiff has not alleged a contract. The complaint alleges “[i]n regard to MMCI and Leon, each of said defendants expressly promised and agreed that upon receipt of further payment from Plaintiffs that they would return to the Property and complete their scope of work. In compliance with said agreements, Plaintiffs did make, in full, the demanded payments to said Defendants as hereinabove alleged.” Complaint ¶27. This sets forth all elements required for formation of a contract. Mendez’s assertion that “[t]here is no contract” is not a valid basis for demurrer. The allegations in the complaint must be treated as true on demurrer. E.g., Brakke v. Economic Concepts, Inc. (2013) 213 Cal.App.4th 761, 767.

 

Mendez argues the contract allegations are ambiguous. Plaintiffs allege defendants promised to finish their work in exchange for payment, plaintiffs paid, but defendants failed to perform. Complaint ¶¶27-29. This is not ambiguous and alleges the elements of breach of contract.  

 

Finally, Mendez argues the complaint does not set forth the terms of a written contract verbatim or attach a copy. This cause of action is based on an alleged oral contract. Mendez provided no authority that the type of contract alleged must be written. In reply, Mendez argues breach of contract liability is unavailable because the contract attached to the complaint does not name them. The breach of contract cause of action against Mendez, however, is not based on that document, but upon a separate oral agreement. OVERRULED.

 

Fraud

Fraud must be pleaded with particularity – the liberal pleading standard does not apply. Lazar v. Superior Court (1996) 12 Cal.4th 631, 645. General pleading of legal conclusions is insufficient to set forth a claim for fraud. Committee on Children’s Television, Inc. v. General Food Corp. (1983) 35 Cal. 3d. 197, 216.

 

Mendez argues the complaint does not allege fraud with the required specificity. The complaint alleges Mendez agreed to return the property and complete work but failed to do so. It alleges conversations between plaintiffs and Mendez Leon “[i]n September and October,” with representations made by defendant Mendez Leon. Complaint ¶¶19-20, 33-35. The complaint alleges he did not intend to complete the work when he made this promise. Id. ¶¶19-21. This is sufficiently specific for purposes of pleading fraud.

 

Finally, Mendez argues the complaint fails to plead the elements of fraud. The complaint alleges a promise made without intent to perform and plaintiffs’ reliance on that promise by paying money. Complaint ¶¶ 19, 34. For purposes of pleading, this is enough to set forth a cause of action for promissory fraud. Mendez’s arguments that the complaint has a “gap in [its] reasoning,” or that plaintiffs owed money are factual contentions not proper on demurrer. At the pleading stage, allegations must be treated as true and, if legally sufficient, the demurrer must be overruled. OVERRULED.

 

Negligent Misrepresentation

The cause of action for negligent misrepresentation against Mendez tracks the factual allegations underlying the fraud cause of action. Complaint at ¶¶43-44. Plaintiff alleges Mendez falsely promised work would be completed in exchange for payment, but Mendez failed to do so. However, there is no cause of action for negligent false promise. E.g., Tarmann v. State Farm Mutual Automobile Insurance Co. (1991) 2 Cal.App.4th 153, 159. Since there is no cause of action for negligent false promise, the demurrer succeeds. SUSTAINED without leave to amend.

 

Motion to Strike

 

Punitive Damages

Mendez moves to strike the request for punitive damages, arguing it is not supported by sufficient facts to show malice. Plaintiffs adequately pleaded a fraud cause of action, which is a sufficient basis to award punitive damages under Cal. Civ. Code §3294(c)(1). DENIED.

 

Alter Ego

Mendez moves to strike the alter ego allegations as conclusory. The court agrees. Plaintiff merely alleges the elements of alter ego liability, without setting forth specific facts. Complaint at pg. 3. These conclusions of law are insufficient to support alter ego liability and must be struck. GRANTED with ten days leave to amend.