Judge: Frank M. Tavelman, Case: 24NNCV03603, Date: 2024-12-20 Tentative Ruling

Case Number: 24NNCV03603    Hearing Date: December 20, 2024    Dept: A

DEMURRER & MOTION TO STRIKE

Los Angeles Superior Court Case # 24NNCV03603

 

MP:  

Burlington Coat Factory of Texas, Inc. (Defendant)

RP:  

Alica Reznic-Alihanjan (Plaintiff)

 

NOTICE:

 

The Court is not requesting oral argument on this matter.  The Court is guided by California Rules of Court, Rule 3.1308(a)(1) whereby notice of intent to appear is requested.  Unless the Court directs argument in the Tentative Ruling, no argument is requested and any party seeking argument should notify all other parties and the court by 4:00 p.m. on the court day before the hearing of the party’s intention to appear and argue.  The tentative ruling will become the ruling of the court if no argument is received.  

 

Notice may be given either by email at BurDeptA@LACourt.org or by telephone at (818) 260-8412.

 

ALLEGATIONS: 

 

Alica Reznic-Alihanjan (Plaintiff) brings this action against Burlington Coat Factory of Texas, Inc. (Defendant). Plaintiff alleges that on August 21, 2023, she was shopping at a store owned by Defendant. (Compl. ¶ 21.) Plaintiff alleges that she tripped on a shelf which was placed outside of its designated area and was severely injured as a result. (Compl. ¶ 22.) Plaintiff’s Complaint states causes of action for (1) Premises Liability, (2) Negligence, (3) Negligent Hiring/Retention and Failure to Warn, and (4) Gross Negligence.

 

Defendant now demurs to the fourth cause of action in the Complaint on grounds that it is not a legally cognizable cause of action. Defendant further demurs to the cause of action on grounds that it is unsupported by sufficient factual allegations. Defendant also moves to strike Plaintiff’s request for punitive damages, located at paragraph 3 in her Prayer for Relief. Plaintiff opposes the demurrer and motion to strike. Defendant replies.

  

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. (Id.)

 

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 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).)

 

II.                 MERITS

 

Meet and Confer

 

C.C.P. §§ 430.41(a) and 435.5(a) requires that the moving party meet and confer with the party who filed the pleading that is subject to the demurrer and/or motion to strike. Upon review the Court finds the meet and confer requirements were met here. (English Decl. ¶¶ 3-4.)

 

Discussion

 

Fourth Cause of Action – Gross Negligence – Sustained with Leave to Amend

 

Defendant demurs to this cause of action on grounds that “gross negligence” is not a legally cognizable cause of action in the State of California. Defendant argues that allegations of gross negligence may be properly leveled as part and parcel of a negligence cause of action, but they do not constitute a separate cause of action. The Court agrees.

 

California does not recognize a distinct common law cause of action for gross negligence apart from negligence. (See Jimenez v. 24 Hour Fitness USA, Inc. (2015) 237 Cal.App.4th 546, 552, fn. 3; Chavez v. 24 Hour Fitness USA, Inc. (2015) 238 Cal.App.4th 632, 640; Eriksson v. Nunnink (2011) 191 Cal.App.4th 826, 856, fn. 18 ["In reality, California does not recognize a distinct cause of action for ‘gross negligence' independent of a statutory basis"].)

 

Numerous cases discuss the doctrine of gross negligence; however, these cases have invariably involved a statute containing the words "gross negligence" in the text. (Cont'l Ins. Co. v. Am. Prot. Indus. (1987) 197 Cal.App.3d 322, 329.) Rather, as a degree of negligence, "[g]ross negligence is pleaded by alleging the traditional elements of negligence: duty, breach, causation, and damages." (Rosencrans v. Dover Images, Ltd. (2011) 192 Cal.App.4th 1072, 1082.) Thus, while gross negligence allegations may be appropriate within a cause of action for negligence, a separate cause of action for gross negligence is not. (See Jimenez, supra, 237 Cal.App.4th at p. 552, fn. 3 [referring to gross negligence as a "degree of negligence"].) Put more succinctly, "Gross negligence is a subspecies of negligence; it is not a separate tort.” (Joshi v. Fitness Int'l, LLC (2022) 80 Cal.App.5th 814, 825.)

 

Here, no statutory basis has been alleged to support the existence of a separate cause of action for gross negligence. Nor has Plaintiff argued that any exists. Accordingly, the demurrer to the fourth cause of action is SUSTAINED with leave to amend.

 

The Court notes that its ruling on this demurrer does not bar Plaintiff from including allegations of gross negligence in their cause of action for ordinary negligence upon amendment. While it appears that there is no reasonable possibility that Plaintiff could amend the Complaint to state a cognizable cause of action for gross negligence, she is still permitted to include allegations of gross negligence under her second cause of action. As such, the Court will briefly address Defendant’s argument that the Complaint falls short of the pleading requirements for gross negligence.  

 

“Gross negligence is pleaded by alleging the traditional elements of negligence: duty, breach, causation, and damages.” (Rosencrans, supra, 192 Cal.App.4th at 1082, citing Jones v. Wells Fargo Bank (2003) 112 Cal.App.4th 1527, 1541.) “However, to set forth a claim for ‘gross negligence’ the plaintiff must allege extreme conduct on the part of the defendant. (Id., citing Eastburn v. Regional Fire Protection Authority (2003) 31 Cal.4th 1175, 1185–1186.) “The conduct alleged must rise to the level of either a want of even scant care or an extreme departure from the ordinary standard of conduct.” (Id., citing City of Santa Barbara v. Superior Court (2007) 41 Cal.4th 747, 754.)

 

The above case law indicates that to properly plead gross negligence, Plaintiff must allege conduct which is extreme and demonstrates a major departure from the ordinary standard of care. While cases have opined on these pleading requirements, they have provided no identifiable standard by which they can be judged on demurrer. For example, in Eastburn v. Regional Fire Protection Authority, the California Supreme Court upheld a demurrer to allegations of gross negligence without leave to amend. The court found, “Plaintiffs have failed to plead facts disclosing any acts of gross negligence or bad faith on the part of defendants or their employees, and they presently assert no additional facts that might justify an amended complaint.” (Eastburn, supra, 31 Cal.4th as 1179.) Despite this holding, the court provided no insight as to how this determination was reached. (Id.)

 

This difficulty is compounded by the fact that courts have held gross negligence to generally be a question of fact, indicating the sufficiency of these allegations is not resolvable upon demurrer. (See Brown v. El Dorado Union High School Dist. (2022) 76 Cal.App.5th 1003, 1028.)

 

Here, Plaintiff’s allegations speaking to gross negligence are identical to her allegations of ordinary negligence. At first glance this indicates that these allegations are insufficient, as they state no separate facts which push Defendant’s actions beyond those of ordinary negligence. Regardless, to conclude at the pleading stage that the alleged actions could never support a claim of gross negligence would appear to be a premature determination of a factual issue. As such, Plaintiffs are not precluded from including allegations of gross negligence upon amendment provided they are not pleaded as a separate cause of action.

 

In summary, the demurrer to the fourth cause of action is SUSTAINED with 20 days’ leave to amend. Leave to amend is granted insofar as Plaintiff may wish to incorporate allegations of gross negligence in her second cause of action. This grant of leave does not permit Plaintiff to restate her separate cause of action for gross negligence.

 

Motion to Strike

 

"In order to survive a motion to strike an allegation of punitive damages, the ultimate facts showing an entitlement to such relief must be pled by a plaintiff. In passing on the correctness of a ruling on a motion to strike, judges read allegations of a pleading subject to a motion to strike as a whole, all parts in their context, and assume their truth." (Clauson v. Superior Court (1998) 67 Cal.App.4th 1253, 1255 (internal citations omitted).) To state a prima facie claim for punitive damages, a plaintiff must allege the elements set forth in the punitive damages statute, Civil Code § 3294. (College Hosp., Inc. v. Superior Court (1994) 8 Cal.4th 704, 721.) Per Civil Code § 3294(a), a plaintiff must allege that the defendant has been guilty of oppression, fraud, or malice. 

 

Here, Plaintiff’s allegations in support of her claim for punitive damages are predicated entirely on her claim of negligence. Plaintiff argues her claim that Defendant negligently placed a shelf in the path of shoppers is sufficient to constitute malice. The Court finds this argument unpersuasive.

 

"Inasmuch as Civil Code Section 3294 requires as a prerequisite to the recovery of punitive damages that the defendant 'has been guilty of oppression, fraud, or malice,' the cases have uniformly recognized that proof of negligence, even gross negligence, or recklessness is insufficient to warrant an award of punitive damages" (Dawes v. Superior Court (1980) 111 Cal.App.3d 82, 87.) Non-intentional conduct can only support a punitive damage award if the defendant intentionally performs an act, and that act is of such severity and shocking character that it warrants the same treatment as that accorded willful misconduct. (Nolin v. National Convenience Stores, Inc. (1979) 95 Cal.App.3d 279.)

 

Plaintiff has alleged no facts beyond those stating non-intentional conduct. Plaintiff’s allegation that Defendant negligently placed a shelf in the path of shoppers does not appear to rise to the level of severity sufficient to support a claim for punitive damages. Nor has Plaintiff demonstrated in opposition that any amendment could cure this deficiency. Accordingly, the motion to strike punitive damages is GRANTED without leave to amend. 

 

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RULING:

 

In the event the parties submit on this tentative ruling, or 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 

 

Burlington Coat Factory of Texas, Inc.’s Demurrer and Motion to Strike came on regularly for hearing on December 20, 2024, with appearances/submissions as noted in the minute order for said hearing, and the court, being fully advised in the premises, did then and there rule as follows: 

 

THE DEMURRER TO THE FOURTH CAUSE OF ACTION IS SUSTAINED WITH 20 DAYS’ LEAVE TO AMEND.

 

THE MOTION TO STRIKE PUNITIVE DAMAGES IS GRANTED WITHOUT LEAVE TO AMEND.  

 

DEFENDANT TO GIVE NOTICE.

 

IT IS SO ORDERED. 

 

DATE:  December 20, 2024                           _______________________________ 

                                                                        F.M. TAVELMAN, Judge 

Superior Court of California 

County of Los Angeles