Judge: Frank M. Tavelman, Case: 22STCV05565, Date: 2023-03-20 Tentative Ruling


SUBMITTING
ON THE TENTATIVE



The Court tries to post tentative rulings prior to any
hearing on many matters, but not all.  If
the parties wish to submit on the tentative ruling and avoid a court
appearance, all counsel must confer and agree to do so.   Each counsel must contact the court and
advise they are submitting on the matter, that they have spoken to opposing
counsel who has indicated they too are submitting and will be calling the
court. All submitting counsel must call Dept A by 9:00 a.m. on the day of the
hearing and state that all parties will submit on the tentative ruling or in lieu
may indicate the party is submitting during calendar check-in and notice of the
ruling must be served as indicated in the tentative. If any party declines to
submit on the tentative ruling, then no telephone call is necessary, and all
parties should appear at the hearing in person or remotely.



 



Case Number: 22STCV05565    Hearing Date: March 20, 2023    Dept: A

THIS IS BEING POSTED ON THE COURT'S TENTAVIE RULING SITE FOR CONVENIENCE OF COUNSEL.  HOWEVER, THIS IS A FINAL RULING AFTER ARGUMENT

LOS ANGELES SUPERIOR COURT

NORTH CENTRAL DISTRICT - BURBANK

DEPARTMENT A

 

FINAL RULING AFTER ARGUMENT

MARCH 20, 2023

 

DEMURRER AND MOTION TO STRIKE

Los Angeles Superior Court Case # 22STCV05565

 

MP:  

Belmont Village Burbank Tenant, LLC; Belmont Three, LLC; Belmont Three Corporation Holding LLC; Belmont Village, L.P. (Defendants)

 

RP:  

Blanche Rivero Maynes, by and through her successor-in-interest, Christina Maynes; Christina Maynes, individually; Lisa Maynes; Philip Maynes (Plaintiffs)

 

ALLEGATIONS: 

 

Plaintiffs Blanche Rivero Maynes, by and through her successor-in-interest, Christina Maynes (“Decedent”); Christina Maynes, individually (“Christina”); Lisa Maynes (“Lisa”); and Philip Maynes (“Philip”, and collectively, “Plaintiffs”) filed suit against Defendants Belmont Village Burbank Tenant, LLC (“BVBT”); Belmont Three LLC (“BT”); Belmont Three Corporation Holding, LLC (“B3CH”); Belmont Village Partners LP (“BVP”); Belmont Village, L.P. (“BV”); Health Care REIT, Inc. (“HCREIT”, and together with BT, B3CH, BVP, and BV, “Belmont Corporate Defendants”; BVBT and Belmont Corporate Defendants together shall be referred to as “Belmont Defendants”); Burbank Healthcare, Inc., d.b.a. Burbank Healthcare & Rehabilitation Center (“Burbank Healthcare”); Burbank Investments, LP (“BI”); Longwood Management Corporation (“LMC”); and Longwood Enterprises, Inc. (“LE”, and together with Burbank Healthcare, BI, and LMC, “Longwood Corporate Defendants”). Plaintiffs allege that Defendants failed to assess and address Decedent’s medical condition and needs when she was admitted by Belmont Village Burbank on July 21, 2020, resulting in her death. 

 

On February 14, 2022, Plaintiff filed an initial Complaint, an on April 21, 2022 filed a First Amended Complaint (“FAC”) which alleges twelve causes of action for: (1) Elder Neglect (against Belmont Defendants); (2) Elder Neglect, Enhanced Remedies (against Belmont Defendants); (3) Elder Neglect (against Longwood Corporate Defendants); (4) Elder Neglect, Enhanced Remedies Sought (against Longwood Corporate Defendants); (5) Negligence (against Belmont Defendants); (6) Negligence (against Longwood Corporate Defendants); (7) Fraud (against Belmont Defendants); (8) Fraud (against Longwood Corporate Defendants); (9) Violation of Patients’ Bill of Rights (against Longwood Corporate Defendants); (10) NIED (against Longwood Corporate Defendants); (11) Wrongful Death (against Belmont Defendants); and (12) Wrongful Death (against Longwood Corporate Defendants).  

 

HISTORY: 

 

Belmont Defendants filed this Demurrer and Motion to Strike on January 4, 2023. Plaintiffs filed their opposition on February 27, 2023. Reply was filed March 3, 2023.  

RELIEF REQUESTED:

 

Belmont Defendants demur to Plaintiffs’ first, second, fifth, seventh, and eleventh cause of action.

 

Belmont Defendants move to strike the following portions of Plaintiffs’ FAC:

 

1.     Page 21, ¶ 53: “reckless, oppressive and malicious”; (Second COA)

2.     Page 22, ¶ 54: “reckless, oppressive, and malicious”; (Second COA)

3.     Page 23, ¶ 56 in its entirety; (Second COA)

4.     Page 25, ¶ 65 in its entirety; (Second COA)

5.     Page 45, ¶ 124: “recklessly”; (Eleventh COA)

6.     Page 47, ¶ 3: “For attorneys’ fees against all defendants pursuant to Welfare and Institutions Code section 15657(a) and Code of Civil Procedure section 1021.5;” (Second COA)

7.     Page 25, ¶ 63: “and attorneys’ fees and costs”; and (Second COA)

8.     Page 47, ¶ 4: “For punitive damages against all defendants.” (All COA)

 

RULING AFTER ARGUMENT:

 

The Court issued its Tentative Ruling.  Plaintiff requested that the Court reconsider its ruling arguing that they sufficiently pled the Cause of Actions.   Plaintiffs requested the Court reevaluate its ruling in light of ¶¶ 14, 15, 39, 40, 47-49, 53, 55 and 57-61.  The Court again reviewed the Plaintiffs First Amended Complaint, paying special attention to the referenced paragraphs as well as applicable CACI instructions.   The Court has done so, and is not convinced to change the Tentative Ruling. 

In Worsham v. O'Connor Hospital, (2014) 226 Cal. App. 4th 331 the Courts of Appeal addressed  similar circumstances.  The plaintiff alleged the hospital knew the elder was a fall risk; the hospital was “chronically understaffed” and undertrained the staff it did have; and the lack of sufficiently well-trained staff caused the decedent's fall. (Id. at pp. 334, 338.) The trial court sustained the hospital's demurrer to the operative complaint, holding that, although the plaintiff alleged the hospital acted recklessly by deliberately understaffing and undertraining, he had not sufficiently supported the allegations with particular facts. (Id. at p. 335.) The appellate court affirmed and held the allegations of failure to provide adequate staffing constituted nothing more than “negligence in the undertaking of medical services, not a ‘fundamental “[f]ailure to provide medical care for physical and mental health needs.”’” (Id. at p. 338, quoting Delaney v. Baker (1999) 20 Cal.4th 23).

The Court having considered the arguments from counsel adopt its tentative as the final ruling.  The Court grants leave amend because the Court believes that Plaintiff is capable of pleading with particularity what is needed.

 

ANALYSIS: 

 

I.                LEGAL STANDARD 

 

Demurrer

 

The grounds for a demurrer must appear on the face of the pleading or from judicially noticeable matters.  (C.C.P. § 430.30(a); Blank v. Kirwan (1985) 39 Cal. 3d 311, 318.) A demurrer for sufficiency tests whether the complaint states a cause of action. (Hahn v. Mirda (2007) 147 Cal.App.4th 740, 747.) The only issue involved in a demurrer hearing is whether the complaint states a cause of action. (Ibid.)

 

A demurrer assumes the truth of all factual, material allegations properly pled in the challenged pleading. (Blank v. Kirwan, supra, 39 Cal. 3d at p. 318.) No matter how unlikely or improbable, the plaintiff’s allegations must be accepted as true for the purpose of ruling on the demurrer. (Del E. Webb Corp. v. Structural Materials Co. (1981) 123 Cal.  App. 3d 593, 604.) But this does not include contentions; deductions; conclusions of fact or law alleged in the complaint; facts impossible in law; or allegations contrary to facts of which a court may take judicial notice.  (Blank, supra, 39 Cal. 3d at p. 318.)

 

Pursuant to C.C.P. §§ 430.10(e) and (f), the party against whom a complaint has been filed may demur to the pleading on the grounds that the pleading does not state facts sufficient to constitute a cause of action, or that the pleading is uncertain, ambiguous and/or unintelligible. It is an abuse of discretion to sustain a demurrer without leave to amend if there is a reasonable probability that the defect can be cured by amendment. (Schifando v. City of Los Angeles (2003) 31 Cal. 4th 1074, 1082.)

 

Motion to Strike

 

Motions to strike are used to reach defects or objections to pleadings that are not challengeable by demurrer, such as words, phrases, and prayers for damages. (See C.C.P. §§ 435, 436, and 437.) The proper procedure to attack false allegations in a pleading is a motion to strike. (C.C.P. § 436(a).) In granting a motion to strike made under C.C.P. § 435, “[t]he court may, upon a motion made pursuant to Section 435 [notice of motion to strike whole or part of complaint], or at any time in its discretion, and upon terms it deems proper: (a) Strike out any irrelevant, false, or improper matter inserted in any pleading.” (C.C.P. § 436(a).) Irrelevant matters include immaterial allegations that are not essential to the claim or those not pertinent to or supported by an otherwise sufficient claim. (C.C.P. § 431.10.) The court may also “[s]trike out all or any part of any pleading not drawn or filed in conformity with the laws of this state, a court rule, or an order of the court.” (C.C.P. § 436 (b).)

 

To succeed on a motion to strike punitive damages allegations, it must be said as a matter of law that the alleged behavior was not so vile, base, or contemptible that it would not be looked down upon and despised by ordinary decent people. (Angie M. v. Superior Court (1995) 37 Cal. App. 4th 1217, 1228-1229.)

Elder Abuse under Welf. & Inst. Code, § 15610.07

To plead elder or dependent adult abuse, the plaintiff must allege “facts establishing that the defendant: (1) had responsibility for meeting the basic needs of the elder or dependent adult, such as nutrition, hydration, hygiene or medical care; (2) knew of conditions that made the elder or dependent adult unable to provide for his or her own basic needs; and (3) denied or withheld goods or services necessary to meet the elder or dependent adult’s basic needs, either with knowledge that injury was substantially certain to befall the elder or dependent adult (if the¿plaintiff¿alleges oppression, fraud or malice) or with conscious disregard of the high probability of such injury (if the plaintiff alleges recklessness) [citations].” (Carter v. Prime Healthcare Paradise Valley LLC¿(2011) 198 Cal.App.4th 396, 406-07.) “The plaintiff must also allege . . . that the neglect caused the elder or dependent adult to suffer physical harm, pain or mental suffering.” (Id.¿at 407.) “[T]he¿facts constituting the neglect and establishing the causal link between the neglect and the injury ‘must be pleaded with particularity,’ in accordance with the pleading rules governing statutory claims.” (Id.¿(quoting¿Covenant Care, Inc. v. Superior Court¿(2004) 32 Cal.4th 771, 790).)¿¿ 

Case law is clear that, “‘neglect’ within the meaning of Welfare and Institutions Code section 15610.57 covers an area of misconduct distinct from ‘professional negligence.’”¿ (Covenant Care, Inc. v. Superior Court¿(2004) 32 Cal.4th 771, 783.)¿ “As used in the Act, neglect refers not to the substandard performance of medical services but, rather, to the ‘failure of those responsible for attending to the basic needs and comforts of elderly or dependent adults, regardless of their professional standing, to carry out their custodial obligations.’”¿ (Id.)¿¿¿ 

 

In order to distinguish Dependent Adult Abuse from Professional¿Negligence, there must be a showing of recklessness, fraud, malice, or oppression. (See¿Covenant Care, Inc., supra, 32 Cal.4th¿at 783.) “Oppression, fraud, and malice involve intentional, willful, or conscious wrongdoing of a despicable or injurious nature.” (Carter v. Prime Healthcare Paradise Valley¿LLC (2011) 198 Cal.App.4th¿396, 405 (internal quotation marks omitted).) Recklessness requires deliberate disregard of a high degree of probability an injury will occur. (Id.) The enhanced remedies for Elder Abuse are only available for “acts of egregious abuse against elder and dependent adults.” (Id.)¿There must be an allegation of authorization or ratification on the part of a managing agent in order to recover damages for dependent adult abuse against corporate defendants. (See Civ. Code, § 3294; Cal.¿Welf. & Inst. Code, § 15657(c).)¿¿ 

 

The Elder Abuse Act “does not apply unless the defendant health care provider had a substantial caretaking or custodial relationship, involving ongoing responsibility for one or more basic needs, with the elder patient.” (Winn v. Pioneer Medical Group, Inc.¿(2016) 63 Cal.4th 148, 152.) “It is the nature of the elder or dependent adult’s relationship with the defendant—not the defendant’s professional standing—that makes the defendant potentially liable for neglect.” (Id.)¿¿¿ 

 

II.              MEET AND CONFER

 

CCP § 430.41(a) requires that the demurring party meet and confer with the party who filed the pleading that is subject to the demurrer at least 5 days before the date the responsive pleading is due, by telephone or in person, for the purpose of determining if the parties can resolve the objections to be raised in the demurrer. The demurring party must file and serve a declaration detailing their meet and confer efforts. Failure to meet and confer is not grounds to overrule or sustain a demurrer, or grant or deny a motion to strike. (CCP §§ 430.41(a)(4); CCP 435.5(a)(4).)

 

Belmont defendants submit the declaration of Thien Tran to evidence their meet and confer efforts. The declaration states that Belmont Defendants sent a letter on March 22, 2022 discussing what they perceived to be the legal and factual insufficiencies of Plaintiffs’ original Complaint. (Tran Decl. ¶ 2.) Plaintiffs thereafter filed their FAC, which the declaration states was unchanged except for the addition of named defendants. (Tran Decl. ¶ 3.) The declaration makes no aversions to further meet and confer efforts or whether Plaintiffs ever responses to the March 22 letter. The Court is uncertain that the efforts extended before the filing of the operative complaint meet Belmont Defendants burden. The Court finds that parties have not complied with the meet and confer requirements, and are admonished to do so in the future.

 

Regardless, failure to meet and confer is not grounds to overrule or sustain a demurrer. The Court will analyze Belmont Defendants demurrer on its merits.

 

III.            MERITS

 

Plaintiff’s Theory of Liability

 

Belmont Defendants arguments about liability appear at the end of their moving papers but, given that these arguments are intended to be demur to the entirety of the FAC, the Court will analyze them first. Belmont Defendants specifically argue the Plaintiffs allege insufficient facts to support holding the Belmont Defendants liable for the alleged conduct of Belmont Village Burbank.

 

Belmont Defendants argue that Plaintiffs have not adequately alleged that Belmont Defendants had care or custody of Decedent such as to support a claim for Elder Neglect. Belmont Defendants argue that Belmont Village Burbank is a Residential Care Facility per Health and Safety Code §1502. Belmont Defendants argue that under California Code of Regulations, Title 22, § 72501, the duty held by resident care facilities is non-delegable. Belmont Defendants cite to California Assn. of Health Facilities v. Department of Health Services (1997) 16 Cal.4th 284 in support of this argument.

 

The Court finds that Belmont Defendants misstate the holding of California Assn. While it is correct that the duty held by licensees under Health and Safety Code §1502 is nondelegable, the Court in California Assn. was specifically addressing the delegation of that duty to employees of the resident care facility. Here, Plaintiff is alleging that Belmont Defendants owe the same duty as the resident care facility by virtue of vicarious liability. The Court does not see how this allegation amounts to one of delegation within the meaning of the statute.

 

Belmont Defendants also argue that Plaintiffs have not adequately alleged theories of vicarious liability. Belmont Defendants specifically address the allegation of alter ego. Belmont Defendants cite to Meadows v. Emett & Chandler (1950) 99 Cal.App.2d 496, in arguing that mere allegations of making all the management decisions do not suffice to claim alter ego. This assertion is correct, but it ignores the remainder of the holding in Meadows. The Meadows court held that allegations of managerial control must be accompanied by facts from which it appears that justice cannot be accomplished without alter ego liability. (Id. at 499.)

 

Courts have held that on demurrer that plaintiffs are only required to allege ultimate facts as to alter ego, as opposed to evidentiary facts. (Rutherford Holdings, LLC v. Plaza Del Rey (2014) 223 Cal.App.4th 221, 236.) Here that means Plaintiffs must plead ultimate facts as to complete managerial control and a resulting injustice in failure to pierce the corporate veil. (Id.) The Court finds that the FAC contains facts as to the managerial control and its allegation that Belmont Village Burbank was “intentionally undercapitalized as a way of avoiding liability” has met the requirements. (FAC ¶¶ 6-10, 16-17.)

 

Plaintiffs further argue in their Opposition that the FAC contains several theories of liability as to Belmont Defendants which are not addressed on Demurrer. These theories include direct liability, joint venture, aider and abettor, and conspiracy. (Oppo. pg. 17.) Belmont Defendants reply that they are not required to challenge all theories of liability but then say that if Demurrer is overruled, they will bring a Motion for Judgment on the Pleadings (MJOP) as to each theory of liability. (Reply pg. 7.) The Court notes that each theory of liability will be subject to factual determination at trial and cautions that Demurrers and MJOPs only address the sufficiency of pleadings.

 

As such the Court finds that Plaintiffs allegations of alter ego are sufficient but makes no determination as to the other theories of liability.

 

The Court will not sustain the demurrer on allegations of alter ego.

 

Plaintiffs’ 1st and 2nd COA (Elder Neglect & Elder Neglect Enhanced Remedies) - Sustained

 

The FAC alleges the following facts. Belmont Defendants were responsible for Decedent’s medical care and knew of the conditions that made Decedent unable to provide for her own basic needs. (FAC, ¶¶ 46.) Belmont Defendants were aware of Decedent’s status as a fall risk and as someone who suffered from dementia. (FAC ¶47.) Belmont Defendants were aware of Decedents tendency to walk herself to the bathroom at night. (Id.) Belmont Defendants failed to carry out care plans related to Decedent’s fall risk. (Id.) That Belmont Defendants controlled staffing decisions and purposefully understaffed to maximize profits over patient care (FAC ¶ 14.) Such understaffing was a pattern of Belmont Defendants, and such pattern was designed to increase their profits. (FAC ¶¶ 14, 15.) Belmont Defendants knew of and ignored the physical threat to Decedent to increase profits. Decedent suffered physical harm that ultimately led to her death. (FAC, ¶¶ 50, 51.) Defendant’s managing agents directly participated in or authorized Decedent’s abuse and neglect. (FAC, ¶¶ 55-57.) 

 

In Fenimore¿v. Regents of University of California¿(2016) 245 Cal.App.4th 1339, the court determined that allegations that a hospital engaged in a pattern and practice of understaffing and undertraining its staff to cut costs, which foreseeably resulted in the abuse and neglect of its residents, were sufficient to state a cause of action under the Elder Abuse Act. The Fenimore court found that:

 

Worsham's determination that understaffing constitutes no more than negligence may be true,¿absent¿further allegations showing recklessness. But the Fenimores have alleged more than a simple understaffing here. The FAC identified the staffing regulation the Hospital allegedly violated and suggested a knowing pattern of violating it constituted recklessness. A jury may see knowingly flouting staffing regulations as part of a pattern and practice to cut costs, thereby endangering the facility's elderly and dependent patients, as qualitatively different than simple negligence”]

 

(Id. at 1350.)

 

The Fenimore court concluded “Recklessness may be inferred when the neglect recurs in a significant pattern.” (Id.) However, the opinion in Fenimore does not describe what sort of pattern or practice would suffice to infer recklessness.

 

Plaintiffs are required to plead facts which allege conduct essentially equivalent to conduct that would support the recovery of punitive damages. (Covenant Care, supra, 32 Cal App. 4th at 789.) Further, Plaintiffs are required to plead their statutory causes of action with particularity (Id. at 790.) The Court finds that Plaintiffs have failed to plead understaffing with sufficient particularity to establish their causes of action for Elder Abuse. Plaintiffs allege that Belmont Defendants engaged in understaffing in a conclusory manner, unlike those in Fenimore which were alleged to be chronic and in violation of particular staffing statutes. The Court recognizes that Plaintiffs allege this understaffing to be in violation of law, but this general statement does not fulfill Plaintiffs’ burden of pleading with particularity. Without further factual allegations related to the understaffing the Court finds the FAC to be insufficiently pled as to Elder Abuse.

 

Plaintiffs suffer a further particularity problem in regards their allegations that Belmont Defendants directly participated in/ratified Decedent’s abuse and neglect. Plaintiff only alleges that unnamed employees served as managing agents for Belmont Defendants and that those managing agents authorized the understaffing that led to neglect. There are no allegations of the managing agents identity or their ability to bind Belmont Defendants. There are also no allegations that the unidentified managing agent was aware of the understaffing or its consequences to Decedent.

 

The Court SUSTAINS the Demurrer as to these two causes of action with 20 days’ leave to amend.

 

Given the above, the Court need not address the parties’ arguments as to whether it was properly alleged that Belmont Defendants had a custodial relationship with decedent.

 

Plaintiffs’ 5th Cause of Action (Negligence)- Overruled

 

In order to state a claim for negligence, a plaintiff must allege the elements of (1) “the existence of a legal duty of care,” (2) “breach of that duty,” and (3) “proximate cause resulting in an injury.” (McIntyre v. Colonies-Pacific, LLC (2014) 228 Cal.App.4th 664, 671.)

 

Belmont Defendants argue that Plaintiffs’ have not alleged sufficient facts to allege causation. Belmont Defendants argue that Plaintiffs’ FAC contains no factual allegations as to what conduct occurred and how that conduct caused Decedents injury. Plaintiffs contend that the FAC does allege facts as to the wrongdoing, namely the failure to implement basic custodial interventions to protect Decedent from falling. (FAC ¶¶ 38-41, 47-50, 89-90.) Plaintiffs argue that Decedent suffered from this fall significant trauma, including a high vertebral fracture. (FAC ¶¶ 41.) Plaintiffs also argue that the FAC does allege Decedent ultimately died from these injuries, speaking to causation. (FAC ¶¶ 43-44, 62, 124.)

 

The Court finds that Plaintiffs have alleged sufficient acts to support their claim of negligence. Belmont Defendants argument that the FAC lack facts as to any action of an individual Belmont Corporate entity relies on having defeated any theory of vicarious liability. Plaintiffs have alleged that the Belmont Defendants are vicariously liable for the conduct of Belmont Village Burbank. Plaintiffs allege that Belmont Village Burbank has a legal duty of care to Decedent, that Belmont Village Burbank breached that duty in failing to prevent Decedent’s fall, and that injuries resulted from that failure. The Court finds these allegations sufficient as to support a cause of action against Belmont Defendants.

 

The Court OVERRULES the demurrer as to the fifth cause of action.

 

Plaintiffs’ 7th Cause of Action (Constructive Fraud) - Sustained

 

“The elements of fraud are (a) a misrepresentation (false representation, concealment, or nondisclosure); (b) scienter or knowledge of its falsity; (c) intent to induce reliance; (d) justifiable reliance; and (e) resulting damage.” (Hinesley v. Oakshade Town Ctr. (2005) 135 Cal.App.4th 289, 294.)

 

“Constructive fraud is a unique species of fraud applicable only to a fiduciary or confidential relationship; generally, constructive fraud comprises any act, omission or concealment involving a breach of legal or equitable duty, trust or confidence which results in damage to another even though the conduct is not otherwise fraudulent.” (Assilzadeh v. California Federal Bank (2000) 82 Cal.App.4th 399, 415.)

 

The facts constituting the alleged fraud must be alleged factually and specifically as to every element of fraud, as the policy of “liberal construction” of the pleadings will not ordinarily be invoked. (Lazar v. Superior Court (1996) 12 Cal.4th 631, 645.) To properly allege fraud against a corporation, the plaintiffs must plead the names of the persons allegedly making the false representations, their authority to speak, to whom they spoke, what they said or wrote, and when it was said or written. (Tarmann v. State Farm Mut. Auto. Ins. Co. (1991) 2 Cal.App.4th 153, 157.)

 

Belmont Defendants argue that Plaintiffs have not pled Fraud with sufficient particularity as per Wilhelm v. Pray, Price, Williams & Russell (1986) 186 Cal.App.3d 1324. Belmont Defendants argue that Plaintiffs have failed to allege facts which support the existence of a fiduciary duty between Belmont Defendants and Decedent. Belmont Defendants cite to Moore v. Regents of the U.C. (1990) 51 Cal.3d 120, stating that care facilities do not have a fiduciary duty to disclose information to a patient. In Moore, the court held that a fiduciary duty to disclose only existed  between physician and patient, and did not extend to non-physician defendants. Further, Belmont Defendants ague that Plaintiffs fail to allege facts as to who breached that fiduciary duty, if it did indeed exist.

 

Plaintiffs argue that “Defendants suggest, without analysis or citation to authority, that Pine Creek Care Center was not in a fiduciary relationship with Mr. Rios.” (Oppo. pg. 15.) The Court presumes this is a typographical error and substitutes the names of the parties in the instant action for the purposes of analyzing Plaintiffs’ argument. Plaintiffs argue that a fiduciary duty can be found where one party has repose trust and confidence in another, citing Barrett v. Bank of America (1986), 183 Cal. App. 3d 1362. Plaintiffs argue that Decedent placed such trust and confidence in Belmont Defendants by virtue of her willing reliance on them for her more basic care needs. Plaintiffs also argue that Moore is distinguishable from the instant case and miscategorized by Belmont Defendants. Plaintiffs argue that unlike in Moore, the allegations against Belmont Defendants did not fail to disclose information but rather to provide care.

 

The Court finds that Moore is informative on this issue. While Moore held that non-physician defendants cannot be said to have a fiduciary relationship, it also held that those defendants could still be held liable for a breach of fiduciary duty under theories of secondary liability. (Moore supra 51 Cal.3d 120, 135.) Plaintiffs here are alleging secondary liability under a number of theories. As such, Belmont Defendants could be held to have breached a fiduciary duty for the purposes of constructive fraud.

 

Regardless, the Court finds that Plaintiffs’ fraud claims are pled with insufficient particularity. Plaintiff alleges no individual which made fraudulent representations, instead averring that the entirety of Belmont Village Burbank misrepresented its ability to care for Decedent. The Court does not find these allegations sufficient to state a cause of action for fraud against a corporation.

 

The Court SUSTAINS the demurrer to the seventh cause of action with 20 days leave to amend.

 

Plaintiffs’ 11th Cause of Action (Wrongful Death) - Overruled

 

“The elements of a cause of action for wrongful death are a tort, such as negligence, and resulting death.” (Lopez v. City of Los Angeles (2011) 196 Cal.App.4th 675, 685.)

Belmont Defendants argue that because Wrongful Death is statutorily created cause of action it must be pled with specificity. Belmont Defendants cite to Norgart v. Upjohn Co. (1999) 21 Cal.4th 383 and Vecchione v. Carlin (1980) 111 Cal.App.3d 351 for the general assertion that Wrongful Death is a statutory cause of action. Neither of these cases address the sufficiency of pleadings on demurrer.  Belmont Defendants do not brief which of the elements of wrongful death that Plaintiffs have not pled with specificity. However, Belmont Defendants do contend that there are no allegations as to a specific wrongful act of each corporate defendant. As discussed in the section addressing the Negligence claim, this argument relies on Belmont Defendants defeating Plaintiffs theory of vicarious liability.

The Court does not find that Plaintiffs have insufficiently pled their cause of action for wrongful death. Plaintiffs have alleged vicarious liability of Belmont Defendants for the actions of Belmont Village Burbank. Plaintiffs have alleged a specific act of wrongdoing which constitutes negligence. Plaintiffs have alleged that Decedent died as a result of injuries sustained due to Belmont Villages Burbank’s failure to provide care.

The Court OVERRULES the demurrer with respect to the eleventh cause of action.

Motion to Strike

 

Cal Civil Code § 3294 (a) states “In an action for the breach of an obligation not arising from contract, where it is proven by clear and convincing evidence that the defendant has been guilty of oppression, fraud, or malice, the plaintiff, in addition to the actual damages, may recover damages for the sake of example and by way of punishing the defendant.”

 

The Court notes that as it has sustained the demurrer with respect to the second cause of action with leave to amend, the motion to strike those portions of the FAC which stem from the second cause of action is moot. These portions include:

 

1.     Page 21, ¶ 53: “reckless, oppressive and malicious”; (Second COA)

2.     Page 22, ¶ 54: “reckless, oppressive, and malicious”; (Second COA)

3.     Page 23, ¶ 56 in its entirety; (Second COA)

4.     Page 25, ¶ 65 in its entirety; (Second COA)

5.     Page 47, ¶ 3: “For attorneys’ fees against all defendants pursuant to Welfare and Institutions Code section 15657(a) and Code of Civil Procedure section 1021.5;” (Second COA)

6.     Page 25, ¶ 63: “and attorneys’ fees and costs”; and (Second COA)

 

This leaves the following portions for the Court to analyze:

 

1.     Page 45, ¶ 124: “recklessly”; (Eleventh COA)

2.     Page 47, ¶ 4: “For punitive damages against all defendants.” (All COA)

 

The Court notes that Belmont Defendants do not individually brief their motion to strike as to the word “recklessly” in Plaintiffs’ eleventh cause of action. The Court finds that the inclusion of recklessness in this cause of action does not speak to any of the elements of a claim for Wrongful Death. As such, the Court orders the word recklessness stricken from the cause of action for irrelevance. The allegations of recklessness do speak to the causes of action for Elder Neglect, but as discussed, the Court has sustained demurrer to these causes of action.

 

The Court also notes that Plaintiffs’ request for punitive damages in the prayer for relief does not specify the basis for these punitive damages. (FAC pg. 47 ¶ 4.) The references to punitive damages in the body of the FAC are confined to the second cause of action. (FAC pg. 23, ¶ 56; pg. 25, ¶ 65.) As such, it appears to the court that the basis for punitive damages in the FAC stems from its causes of action for elder abuse. As the Court has sustained demurrer to those causes of action with leave to amend, the motion to strike punitive damages from the prayer for relief is moot.

 

IV.           CONCLUSION

 

The matte was taken under submission after argument.   The Court adopts its Tentative Ruling as the Final ruling for the reasons stated above.

 

As such the Court finds that Plaintiffs allegations of alter ego are insufficient but makes no determination as to the other theories of liability. The Court OVERRULES the demurrer as to the allegations of alter ego. The Court SUSTAINS the Demurrer as to these two causes of action with 20 days leave to amend. The Court OVERRULES the demurrer as to the fifth cause of action. The Court SUSTAINS the demurrer to the seventh cause of action with 20 days leave to amend. The Court OVERRULES the demurrer with respect to the eleventh cause of action.

The motion to strike is GRANTED as to the word reckless in the eleventh cause of action. The remainder of the motion to strike is moot as the Court sustained demurrer on the causes of action for Elder Abuse and Fraud.

--- 

 

RULING:

 

In the event a party requests a signed order or the court in its discretion elects to sign a formal order, the following form will be either electronically signed or signed in hard copy and entered into the court’s records. 

 

ORDER 

 

Belmont Village Burbank Tenant, LLC; Belmont Three, LLC; Belmont Three Corporation Holding LLC; Belmont Village, L.P. ’s Demurrer and Motion to Strike came on regularly for hearing on March 10, 2023, with appearances/submissions as noted in the minute order for said hearing, and the court, being fully advised in the premises.  The Court heard argument and took the matter under submission and rules as follows: 

 

THE COURT OVERRULES THE DEMURRER AS TO THE ALLEGATIONS OF ALTER EGO.

THE COURT SUSTAINS THE DEMURRER AS TO THE FIRST, SECOND AND SEVENTH CAUSES OF ACTION WITH 20’ DAYS LEAVE TO AMEND.

THE COURT OVERRULES THE DEMURRER AS TO THE FIFTH AND ELEVENTH CAUSES OF ACTION.

THE MOTION TO STRIKE IS GRANTED AS TO THE WORD “RECKLESS” IN THE ELEVENTH CAUSE OF ACTION.

THE REMAINDER OF THE MOTION TO STRIKE IS MOOT AS THE COURT SUSTAINED DEMURRER ON THE CAUSES OF ACTION FOR ELDER ABUSE AND FRAUD.

DEFENDANT TO GIVE NOTICE, UNLESS ALL PARTIES WAIVED NOTICE.

 

IT IS SO ORDERED. 

 

DATE: March 20, 2023                            _______________________________ 

                                                                        F.M. TAVELMAN, Judge 

Superior Court of California 

County of Los Angeles