Judge: Gail Killefer, Case: 20STCV38707, Date: 2022-08-05 Tentative Ruling

Case Number: 20STCV38707    Hearing Date: August 5, 2022    Dept: 37

HEARING DATE:                 August 5, 2022

CASE NUMBER:                  20STCV38707

CASE NAME:                        Jeremy Rosenberg, et al. v. Autumn Lorenz, et al. 

MOVING PARTIES:             Cross-Defendants, Jeremy Rosenberg and Joanna Cohen

OPPOSING PARTY:             Cross-Complainant, Autumn Lorenz; Defendants Pres.Now, Inc.,  Bob Herrera, Nina Plotner

TRIAL DATE:                        September 20, 2022

PROOF OF SERVICE:          OK 

                                                                                                                                                           

MOTION:                               Motion for Summary Judgment as to Third Amended Cross-Complaint; Motion for Summary Judgment as to 26th Affirmative Defense

OPPOSITION:                       July 19-21, 2022  

REPLY:                                  July 21-25, 2022

                                                                                                                                                           

TENTATIVE:                         Cross-Defendants’ motion is denied. Cross-Defendants are to give notice. 

                                                                                                                                                           

Background

This action arises out of Plaintiffs, Joanna Cohen (“Cohen”) and Jeremy Rosenberg’s (“Rosenberg”) lease of real property located at 7601 Midfield Avenue, Los Angeles, California (the “Midfield Property”).  Plaintiffs allege that Defendant, Autumn Lorenz (“Lorenz”) is the owner of the Midfield Property, Defendant Nina Plotner (“Plotner”) is its manager, and Defendant Bob Herrera (“Herrera”) is a real estate broker for the Midfield Property through his firm, Defendant Pres. Now, Inc. dba Professional Real Estate Services (“Management Firm”).

Plaintiffs allege that each of them qualifies as having a disability under the Fair Employment and Housing Act. According to Plaintiffs, they began a romantic relationship on or about May 30, 2017 and thereafter decided to adopt a mini pig as an emotional support animal. On or about September 12, 2019, Plaintiffs signed a lease with Lorenz for the Midfield Property, which allegedly included a Pet Addendum permitting Plaintiffs to keep their mini pig for an additional security deposit. After Plaintiffs moved into the Midfield Property, Plaintiffs allege that they repeatedly received improper demands regarding their mini pig and to vacate the property, despite the lease and pet addendum allegedly permitting the mini pig. Plaintiffs further allege that they provided documentation in response to these demands that their mini pig was an emotional support animal which posed no health and safety risk but that despite this, Defendants continued to unreasonably withhold consent for them to keep their mini pig. Finally, Plaintiffs allege that Defendants posted a three-day Notice to Perform Conditions and Covenants or Quit (the “Notice”) on December 8, 2019, but that the Notice was wrongful as it failed to make any specific demands about covenants to fulfill and was based on fabricated evidence about Plaintiffs’ wrongdoing.

Plaintiffs’ Complaint alleges the following causes of action: (1) housing discrimination (Government Code § 12955), (2) Unruh Civil Rights Act (Civil Code §§ 51, 52), (3) Bane Act (Civil Code § 52.1), (4) retaliation (Government Code § 12855.7), (5) conspiracy, (6) breach of implied covenant of quiet enjoyment against Lorenz, (7) breach of contract against Lorenz, (8) breach of implied covenant of good faith and fair dealing against Lorenz, (9) intentional interference with economic relations against Plotner, Herrera and Management Firm, (10) intentional infliction of emotional distress.

On March 26, 2021, Plaintiffs filed their First Amended Complaint. (“FAC”) The FAC removes the third and fifth causes of action. On June 4, 2021, Plaintiffs filed their operative Second Amended Complaint (“SAC”), adding an eleventh cause of action for fraud against Lorenz.

On July 2, 2021, Plotner, Herrera, and Management Firm (“Management Defendants”) filed their Answer to the SAC, including a 26th Affirmative Defense under the Agent Immunity Rule. Management Defendants allege immunity from liability, contending they were acting as property managers on behalf of and under the authorization of Lorenz.

On April 22, 2021, Lorenz filed a Cross-Complaint against Rosenberg and Cohen (“Cross-Defendants”), alleging that their actions in keeping a mini pig at the Midfield Property constituted a breach of the lease. Lorenz’s cross-complaint alleges the following causes of action: (1) Breach of contract, (2) negligence, (3) fraud, (4) negligent infliction of emotional distress and (5) intentional infliction of emotional distress.

On December 7, 2021, Lorenz filed the Second Amended Cross-Complaint. (“SACC”) The SACC alleged only the first four causes of action.  On March 30, 2022, Lorenz filed the operative Third Amended Cross-Complaint (“TACC”) again alleging the first four causes of action. On May 26, 2022, the court sustained Cross-Defendants’ demurrer without leave to amend as to the third cause of action of the TACC.

Cross-Defendants now move for summary judgment against Lorenz on all remaining causes of action. Lorenz opposes the motion.

Cross-Defendants also move for summary judgment as to the 26th Affirmative Defense alleged by Management Defendants. Management Defendants oppose the motion.

As the motions relate to the same general set of facts, the court considers both motions together.

Cross-Defendants now move for summary judgment or, in the alternative, summary adjudication on all of the following issues:

1.      Lorenz’s first cause of action for breach of contract is without merit because a breach of a contract and damages do not exist; 

 

2.      Lorenz’s second cause of action for negligence is further without merit because it is barred by the economic loss doctrine;

 

3.      Lorenz’s third cause of action is further without merit because Lorenz cannot establish any concealment occurred;

 

4.      Lorenz’s fourth cause of action for negligent infliction of emotional distress is also without merit because Cross-Defendants did not owe Lorenz a duty and did not proximately cause her damages; and

 

5.       Management Defendants’ 26th Affirmative Defense of Agent Immunity Rule is without merit as it is not supported by facts.

 

Cross-Defendants’ Notice of Motion is deficient in that it moves for adjudication as to the third cause of action of the TACC, which the court has already sustained on demurrer. As such, the court disregards Cross-Defendants’ arguments as surplusage.

 

Request for Judicial Notice 

Cross-Defendants request untimely and late judicial notice of the following in reply in support of their motion: 

  1. Exhibit 1: Article published on Well+Good, October 15, 2019, “Women Need to Stop Believing the Myth that Stress Causes Miscarriage.”
  2. Exhibit 2: Mayo Clinic, updated January 22, 2022, “Can too much stress cause early miscarriage?”
  3. Exhibit 3: American College of Obstetricans and Gynecologists, last updated January 2022, Early Pregnancy Loss, FAQ090.
  4. Exhibit 4: Cleveland Clinic, reviewed July 19, 2022, “Miscarriage.”
  5. Exhibit 5: Qu F, Wu Y, Zhu YH, et al. “The association between psychological stress and miscarriage: A systematic review and meta-analysis.” Sci Rep 7, 1731 (2017). May 11, 2017. https://www.nature.com/articles/s41598-017-01792-3.
  6. Exhibit 6: Massey AJ, Campbell B, et al. “The association of physiological cortisol and IVF treatment outcomes: a systematic review. Reprod Med Biol. 13:161-176 (2014). April 11, 2014. https://onlinelibrary.wiley.com/doi/epdf/10.1007/s12522-014-0179-z.
  7. Exhibit 7: Anne-Marie Nybo Anderson et al. International Journal of Epidemiology, Volume 41, Issue 2, April 2012, Pages 405–413, https://doi.org/10.1093/ije/dyr189.
  8. Exhibit 8: Andrea Kemp, M.D. GoodRx Health. April 1, 2022. https://www.goodrx.com/health-topic/parenthoodpregnancy/can-stress-cause-miscarriage
  9. Exhibit 9: Tenants who are unaware of their landlord’s pregnancy cannot foresee a loss caused by their conduct that includes living at their rental property with their emotional support animal.

 

Request no. 9 is rejected outright as no exhibit or document is introduced for judicial notice, rather Cross-Defendants seek to take judicial notice of a contention, outside of proper methods.

Lorenz opposes the requests and contends they are unauthenticated, partial portions of any relevant documents. (RJN Opp., 2.)

The court agrees. Cross-Defendants have failed to show how they have complied with Cal. Evid. Code § 452 and 453, have failed to authenticate the documents or explain them to be proper matters for judicial notice, and have failed to provide justifications altogether. Aside from these failures, Cross-Defendants have failed to attach the documents to the request altogether, instead asking the court to conduct a fishing expedition to find the documents they are referencing. The court refuses to waste further judicial resources on such matters. The request is therefore denied.

Cross-Defendants’ Objections

 

In defiance of Cal. Rules of Court Rule 3.1354, Cross-Defendants again have submitted evidentiary objections without following one of the two allowed formats—namely, Cross-Defendants fail to number the objections and as such, fail to accurately refer to each objection individually. As such, the court is tempted to overrule the objections entirely.  Nonetheless, the court rules as follows:

Objections to the Declaration of Autumn Lorenz

Overruled: 1-8, 10-12, 14-18

Sustained in part: 13, 19

Sustained: 9

Objections to the Declaration of Bob Herrera

Sustained in part: 6

Overruled: All remaining objections.  

Management Defendants’ Objections

In defiance of Cal. Rules of Court Rule 3.1354, Management Defendants also have submitted evidentiary objections without following one of the two allowed formats—namely, Management Defendants fail to number the objections and fail to quote or set forth the objectionable statement or material. Therefore, they fail to accurately refer to each objection individually. As such, the court is tempted to overrule the objections entirely.  Nonetheless, the court rules as follows:

Objection 1-4: overruled.

Objection 5: sustained.    

Discussion

                   I.            Legal Authority 

“The purpose of the law of summary judgment is to provide courts with a mechanism to cut through the parties' pleadings in order to determine whether, despite their allegations, trial is in fact necessary to resolve their dispute.”  (Aguilar v. Atlantic Richfield Co. (2001) 25 Cal.4th 826, 843.)  Pursuant to CCP § 437c(a): 

 

A party may move for summary judgment in any action or proceeding if it is contended that the action has no merit or that there is no defense to the action or proceeding.  The motion may be made at any time after 60 days have elapsed since the general appearance in the action or proceeding of each party against whom the motion is directed or at any earlier time after the general appearance that the court, with or without notice and upon good cause shown, may direct….  The motion shall be heard no later than 30 days before the date of trial, unless the court for good cause orders otherwise.  The filing of the motion shall not extend the time within which a party must otherwise file a responsive pleading. 

 

A motion for summary judgment may be granted “if all the papers submitted show that there is no triable issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.”  (CCP § 437c(c).)   

 

“The motion shall be supported by affidavits, declarations, admissions, answers to interrogatories, depositions, and matters of which judicial notice shall or may be taken.  The supporting papers shall include a separate statement setting forth plainly and concisely all material facts that the moving party contends are undisputed.  Each of the material facts stated shall be followed by a reference to the supporting evidence.  The failure to comply with this requirement of a separate statement may in the court’s discretion constitute a sufficient ground for denial of the motion.”  (CCP § 437c(b)(1); see also Cal. Rules of Court, rule 3.1350(c)(2) & (d).)   

 

“A party may move for summary adjudication as to one or more causes of action within an action, one or more affirmative defenses, one or more claims for damages, or one or more issues of duty, if the party contends that the cause of action has no merit, that there is no affirmative defense to the cause of action, that there is no merit to an affirmative defense as to any cause of action, that there is no merit to a claim for damages, as specified in Section 3294 of the Civil Code, or that one or more defendants either owed or did not owe a duty to the plaintiff or plaintiffs.” 

(CCP § 437c(f)(1).) 

 

“Notwithstanding subdivision (f), a party may move for summary adjudication of a legal issue or a claim for damages other than punitive damages that does not completely dispose of a cause of action, affirmative defense, or issue of duty pursuant to this subdivision.” (CCP § 437c(t).) 

 

In analyzing motions for summary judgment, courts must apply a three-step analysis: “(1) identify the issues framed by the pleadings; (2) determine whether the moving party has negated the opponent's claims; and (3) determine whether the opposition has demonstrated the existence of a triable, material factual issue.”  (Hinesley v. Oakshade Town Center (2005) 135 Cal.App.4th 289, 294 (Hinesley).)  Pursuant to CCP § 437c(p)(2): 

 

A defendant or cross-defendant has met his or her burden of showing that a cause of action has no merit if the party has shown that one or more elements of the cause of action, even if not separately pleaded, cannot be established, or that there is a complete defense to the cause of action.  Once the defendant or cross-defendant has met that burden, the burden shifts to the plaintiff or cross-complainant to show that a triable issue of one or more material facts exists as to the cause of action or a defense thereto.  The plaintiff or cross-complainant shall not rely upon the allegations or denials of its pleadings to show that a triable issue of material fact exists but, instead, shall set forth the specific facts showing that a triable issue of material fact exists as to the cause of action or a defense thereto. 

 

(CCP § 437c(p)(2).)  The court must “view the evidence in the light most favorable to the opposing party and accept all inferences reasonably drawn therefrom.”  (Hinesley, 135 Cal.App.4th at p. 294; Dore v. Arnold Worldwide, Inc. (2006) 39 Cal.4th 384, 389 [Courts “liberally construe the evidence in support of the party opposing summary judgment and resolve doubts concerning the evidence in favor of that party.”].)  A motion for summary judgment must be denied where the moving party’s evidence does not prove all material facts, even in the absence of any opposition (Leyva v. Sup. Ct. (1985) 164 Cal.App.3d 462, 475) or where the opposition is weak (Salasguevara v. Wyeth Labs., Inc. (1990) 222 Cal.App.3d 379, 384, 387).   

 

                II.            Factual Summary

 

The TACC incorporates by exhibit the Lease Agreement signed between Cross-Defendants and Lorenz, which underpins Lorenz’s claims against Cross-Defendants. The Lease Agreement states in relevant part:

“1B. The Premises are for the sole use as a personal residence by the following named person(s) only: Joanna Cohen, Jeremy Rosenberg.

...

11.       MAINTENANCE USE AND REPORTING:

A.        Tenant shall properly use, operate and safeguard Premises, including if applicable, any landscaping, furniture, furnishings and appliances, and all mechanical, electrical, gas and plumbing fixtures, carbon monoxide detector(s) and smoke alarms, and keep them and the Premises clean, sanitary and well ventilated. Tenant shall be responsible for checking and maintaining all carbon monoxide detectors and any additional phone lines beyond the one line and jack that Landlord shall provide and maintain. Tenant shall replace any burned out or malfunctioning light bulbs. Tenant shall immediately notify Landlord, in writing, of any problem, malfunction or damage with any item including carbon monoxide detector(s) and smoke alarms on the property. Tenant shall be charged for all repairs or replacements caused by Tenant, pets, guests or licensees of Tenant, excluding ordinary wear and tear. Tenant shall be charged for all damage to Premises as a result of failure to report a problem in a timely manner. Tenant shall be charged for repair _of drain blockages or stoppages, unless caused by defective plumbing parts or tree roots invading sewer lines.

B. [] Landlord [X] Tenant shall water the garden, landscaping, trees and shrubs, except: -

C. [X] Landlord []Tenant shall maintain the garden, landscaping, trees and shrubs, except:

...

12.       NEIGHBORHOOD CONDITIONS: Tenant is advised to satisfy himself or herself as to neighborhood or area conditions, including, but not limited to, schools, proximity and adequacy of law enforcement, crime statistics, proximity of registered felons or offenders, fire protection, other governmental services, availability, adequacy and cost of any wired, wireless internet connections or other telecommunications or other technology services and installations, proximity to commercial, industrial or agricultural activities, existing and proposed transportation, construction and development that may affect noise, view, or traffic, airport noise, noise or odor from any source, wild and domestic animals, other nuisances, hazards, or circumstances, cemeteries, facilities and condition of common areas, conditions and influences of significance to certain cultures and/or religions, and personal needs, requirements and preferences of Tenant

13.       PETS: Unless otherwise provided in California Civil Code §54.2, or other law, no animal or pet shall be kept on or about the Premises without Landlord's prior written consent, [X] except as agreed to in the attached Pet Addendum (C.A.R. Form PET).

...

17.       ALTERATIONS; REPAIRS: Unless otherwise specified by law or paragraph 25C, without Landlord's prior written consent, (I) Tenant shall not make any repairs, alterations or improvements in or about the Premises induding: painting, wallpapering, adding or changing locks, installing antenna or satellite dish(es), placing signs, displays or exhibits, or using screws, fastening devices, large nails or adhesive materials; (ii) Landlord shall not be responsible for the costs of alterations or repairs made by Tenant; (iii) Tenant shall not deduct from Rent the costs of any repairs, alterations or improvements; and (iv) any deduction made by Tenant shall be considered unpaid Rent.

...

19.       ENTRY:

A.        Tenant shall make Premises available to Landlord or Landlord's representative for the purpose of entering to make necessary or agreed repairs (including, but not limited to, installing, repairing, testing, and maintaining smoke detectors and carbon monoxide devices, and bracing, anchoring or strapping water heaters, or repairing dilapidation relating to the presence of mold); providing decorations, alterations, or improvements, or supplying necessary or agreed services; or to show Premises to prospective or actual purchasers, tenants, mortgagees, lenders, appraisers, contractors and others (collectively "Interested Persons"). Tenant agrees that Landlord, Broker and Interested Persons may take photos of the Premises.

B.        Landlord and Tenant agree that 24-hour written notice shall be reasonable and sufficient notice, except as follows: (1) 48-hour written notice is required to conduct an inspection of the Premises prior to the Tenant moving out, unless the Tenant waives the right to such notice. (2) If Landlord has in writing informed Tenant that the Premises are for sale and that Tenant will be notified orally to show the premises (C.A.R. Form NSE), then, for the next 120 days following the delivery of the NSE, notice may be given orally to show the Premises to actual or prospective purchasers. (3) No written notice is required if Landlord and Tenant orally agree to an entry for agreed services or repairs if the date and time of entry are within one week of the oral agreement. (4) No notice is required: (i) to enter in case of an emergency; (ii) if the Tenant is present and consents at the time of entry; or (iii) if the Tenant has abandoned or surrendered the Premises.

C.        D (If checked) Tenant authorizes the use of a keysafe/lockbox to allow entry into the Premises and agrees to sign a keysafe/lockbox addendum (C.A.R. Form KLA).

...

22.       ASSIGNMENT; SUBLETTING: A. Tenant shall not sublet all or any part of Premises, or parking or storage spaces, or assign or transfer this Agreement or any interest in it, without Landlord's prior written consent. Unless such consent is obtained, any assignment, transfer or subletting of Premises or this Agreement or tenancy, by voluntary act of Tenant, operation of law or otherwise, shall, at the option of Landlord, terminate this Agreement. Any proposed assignee, transferee or sublessee shall submit to Landlord an application and credit information for Landlord's approval and, if approved, sign a separate written agreement with Landlord and Tenant. Landlord's consent to any one assignment, transfer or sublease, shall not be construed as consent to any subsequent assignment, transfer or sublease and does not release Tenant of Tenant's obligations under this Agreement. B. This prohibition also applies ( D does not apply) to short term, vacation, and transient rentals such as, but not limited to, those arranged through AirBnB, VRB.

...

25.       TENANT’S OBLIGATIONS UPON VACATING PREMISES:

A.        Upon termination of this Agreement, Tenant shall: (i) give Landlord all copies of all keys and any opening devices to Premises, including any common areas; (ii) vacate and surrender Premises to Landlord, empty of all persons; and personal property belonging to Tenant (iii) vacate any/all parking and/or storage space; (iv) clean and deliver Premises, as specified in paragraph C below, to Landlord in the same condition as referenced in paragraph 10; (v) remove all debris; (vi) give written notice to Landlord of Tenant's forwarding address; and (vii) _________________________ .

B.        All alterations/improvements made by or caused to be made by Tenant, with or without Landlord's consent, become the property of Landlord upon termination. Landlord may charge Tenant for restoration of the Premises to the condition it was in prior to any alterations/improvements.

C.        Right to Pre-Move-Out Inspection and Repairs: (i) After giving or receiving notice of termination of a tenancy (C.A.R. Form NTT), or before the expiration of this Agreement, Tenant has the right to request that an inspection of the Premises take place prior to termination of the lease or rental (CAR. Form NRI). If Tenant requests such an inspection, Tenant shall be given an opportunity to remedy identified deficiencies prior to termination, consistent with the terms of this Agreement. (ii) Any repairs or alterations made to the Premises as a result of this inspection (collectively, "Repairs") shall be made at Tenant's expense. Repairs may be performed by Tenant or through others, who have adequate insurance and licenses and are approved by Landlord. The work shall comply with applicable law, including governmental permit, inspection and approval requirements. Repairs shall be performed in a good, skillful manner appearance with or materials cosmetic of items quality following and all appearance Repairs may not comparable be to possible. existing (iii) Tenant materials. shall: It is (a) obtain understood receipts that for exact Repairs restoration performedof by others; (b) prepare a written statement indicating the Repairs performed by Tenant and the date of such Repairs; and (c) provide copies of receipts and statements to Landlord prior to termination. Paragraph 25C does not apply when the tenancy is terminated pursuant to California Code of Civil Procedure § 1161 (2), (3), or (4 ).

...

28.       DAMAGE TO PREMISES:

If, by no fault of Tenant, Premises are totally or partially damaged or destroyed by fire, earthquake, accident or other casualty that render Premises totally or partially uninhabitable, either Landlord or Tenant may terminate this Agreement by giving the other written notice. Rent shall be abated as of the date Premises become totally or partially uninhabitable. The abated amount shall be the current monthly Rent prorated on a 30-day period. If the Agreement is not terminated, Landlord shall promptly repair the damage, and Rent shall be reduced based on the extent to which the damage interferes with Tenant’s reasonable use of Premises. If damage occurs as a result of an act of Tenant or Tenant’s guests, only Landlord shall have the right of termination, and no reduction in Rent shall be made.

...

34.       REPRESENTATION

A.        TENANT REPRESENTATION; OBLIGATIONS REGARDING OCCUPANTS; CREDIT: Tenant warrants that all statements in Tenant's rental application are accurate. Landlord requires all occupants 18 years of age or older and all emancipated minors to complete a lease rental application. Tenant acknowledges this requirement and agrees to notify Landlord when any occupant of the Premises reaches the age of 18 or becomes an emancipated minor. Tenant authorizes Landlord and Broker(s) to obtain Tenant's credit report periodically during the tenancy in connection with the modification or enforcement of this Agreement. Landlord may cancel this Agreement: (i) before occupancy begins; upon disapproval of the credit report(s), or upon discovering that information in Tenant's application is false; (ii) After commencement date, upon disapproval of an updated credit report or upon discovering that information in Tenant's application is no longer true. A negative credit report reflecting on Tenant's record may be submitted to a credit reporting agency if Tenant fails to fulfill the terms of payment and other obligations under this Agreement.

...

40.       AGENCY:

A.        CONFIRMATION: The following agency relationship(s) are hereby confirmed for this transaction:

Listing Agent: (Print firm name) PRES.NOW. Inc dba as Professional Real Estate Services

is the agent of (check one):[] the Landlord exclusively; or [X] both the Landlord and Tenant.

Leasing Agent: (Print firm name) PRES.NOW. Inc dba as Professional  Real Estate Services

(if not same as Listing Agent) is the _agent of ( check one): [] the Tenant exclusively; or [] the Landlord exclusively; or [X] both the Tenant and Landlord.

...

PET ADDENDUM

PET ADDENDUM AND AGREEMENT:

Notwithstanding any other term in the Agreement, Landlord herewith grants permission for Tenant to have the following

pet(s) only on the Premises:1 pet  subject to the following terms and conditions:

1.         Tenant is not allowed to have any other pets on the Premises other than those designated above, including any pets that are "just visiting."

2.         Tenant represents to Landlord that the pet(s) is housebroken, has no vicious tendencies or history of threatening or causing harm to persons by biting, scratching, chewing or otherwise.

3.         Tenant agrees that the pet(s) will be properly licensed and vaccinated pursuant to applicable laws and Tenant further agrees to provide proof of licensing and vaccination upon Landlord's or agent's request.

4.         Tenant is responsible for compliance with all local laws and regulations relating to the pets.

5.         Tenant agrees to clean up after their pet(s) and properly dispose of all waste.

6.         Tenant agrees to keep Premises free from pet odor and stain.

7.         Tenant agrees to take action to avoid pest infestations (fleas, etc.) in the Premises.

8.         If the Premises is part of a residential complex, pets are not allowed in pool areas, clubhouses, business office, laundry rooms, business center or fitness centers. Pets may not be bathed or groomed in the laundry room sinks, pools, or pool area.

9.         Permission to have a pet may be revoked at any time with three days notice for cause, or for month to month tenancies with thirty days notice without cause. Tenant's failure to remove the pet(s) after permission has been revoked shall be deemed a breach of the lease or rental agreement.

10.       Tenant is responsible for and will be charged for any damage to the Premises caused by their pet(s), whether listed above or "just visiting." Damages include, but are not limited to, damages to floors, carpets, drapes, screens, landscaping, fencing, including odors due to the presence of pets.

11.       Tenant agrees to indemnify and hold Landlord and Landlord's agents harmless from all liability, claims, demands, damages and costs for injuries to persons or property in connection with Tenant's pet(s).”

(TACC, Exh. A.)

             III.            Analysis 

 

a.      First Cause of Action: Breach of Contract

 

A cause of action for¿breach of contract consists of the following elements: (1) the existence of a contract; (2) the plaintiff’s performance or excuse for nonperformance; (3) the defendant’s breach; and (4) the resulting damages to the plaintiff.¿ (Oasis West Realty, LLC v. Goldman¿(2011) 51 Cal.4th 811, 821.)¿“The essence of a contract is the meeting of minds on the essential features of the agreement.” (Krasley¿v. Superior Court¿(1980) 101 Cal.App.3d 425, 431.) A contract “is unenforceable if the parties fail to agree on a material term or if a material term is not reasonably certain.” (Lindsay v. Lewandowski¿(2006) 139 Cal.App.4th 1618, 1623.)¿ 

 

“A party may rescind a contract if his or her consent was given by mistake.” (Donovan v.¿RRL¿Corp.¿(2001) 26 Cal.4th 261, 278.) “A factual mistake by one party to a contract, or unilateral mistake, affords a ground for rescission in some circumstances.” (Id.) Additionally, CCP § 1689 provides the following grounds for a party to rescind a contract: 

 

(a)¿A contract may be rescinded if all the parties thereto consent. 

(b)¿A party to a contract may rescind the contract in the following cases: 

(1)¿If the consent of the party rescinding, or of any party jointly contracting with him, was given by mistake, or obtained through duress, menace, fraud, or undue influence, exercised by or with the connivance of the party as to whom he rescinds, or of any other party to the contract jointly interested with such party. 

(2)¿If the consideration for the obligation of the rescinding party fails, in whole or in part, through the fault of the party as to whom he rescinds. 

(3)¿If the consideration for the obligation of the rescinding party becomes entirely void from any cause. 

(4)¿If the consideration for the obligation of the rescinding party, before it is rendered to him, fails in a material respect from any cause. 

(5)¿If the contract is unlawful for causes which do not appear in its terms or conditions, and the parties are not equally at fault. 

(6)¿If the public interest will be prejudiced by permitting the contract to stand. 

(7)¿Under the circumstances provided for in Sections 39, 1533, 1566, 1785, 1789, 1930 and 2314 of this code, Section 2470 of the Corporations Code, Sections 331, 338, 359, 447, 1904 and 2030 of the Insurance Code or any other statute providing for rescission. 

 

Cross-Defendants contend the first cause of action is without merit as there are no triable issues of material fact regarding the breach element of Lorenz’s claims. (Motion, 3.)

Cross-Defendants first contend that the TACC’s assertion of a duty to “maintain the premises” is ambiguous, as Lorenz had an obligation to maintain the garden and landscaping, and the Agreement provided for “wear and tear.” (Motion, 4.) Cross-Defendants assert no evidence proffered by Lorenz “evidence a breach,” as they attest to watering the lawn as required, and completed any repairs requested. Cross-Defendants also point out that they received their full security deposit, were “never informed” “of estimated future repairs,” were never charged for any future repairs, and were never sent an itemized statement of costs for any repairs which were made. (Id.) Cross-Defendants simply point to these as “undisputed” facts, with no supporting authority or explanations as to their claims.

 

Cross-Defendants also contend that Lorenz “was aware of a potential roommate prior” to the execution of the Lease, and Cross-Defendants relied on Lorenz’s “pre-approval” in moving forward with allowing a new roommate to enter the residence. (Motion, 5.) Cross-Defendants also contend that Lorenz’s disapproval of any roommate “was about the pig,” and contend that Lorenz did not follow the Lease procedures for a proposed roommate. (Id.) They allege the denial of the potential roommate “was unreasonable.” Again, Cross-Defendants make conclusory allegations regarding what is “undisputed,” without supporting authorities or explanations.

 

Cross-Defendants further contend that the “purported alterations or modifications,” including security cameras and gate locks did not cause any damage to Lorenz and were not a breach of their duties and obligations. (Motion, 6.) Cross-Defendants also contend that Lorenz’s request to enter the residence was actually “inspecting the premises for damages” which Cross-Defendants contend “is an improper purpose for a landlord to enter a lease property.” (Motion, 6-7.) Again, Cross-Defendants make these conclusory allegations without supporting authority, in spite of Paragraph 19(A) of the Lease Agreement stating explicitly that entry into the premises could be requested for “supplying necessary or agreed services.” (TACC, Exh. A, ¶19(A).) Cross-Defendants also contend that they did not breach the Agreement by refusing an inspection of the leased property nearly six months prior to their move-out date. (Motion, 7.) Cross-Defendants also contend they “satisfied” themselves of the neighborhood conditions, in a manner that does not constitute a breach of the Agreement, as required by ¶ 12 of the Agreement. (Id.)

 

Cross-Defendants also contend that “an emotional support animal is not a pet,” citing 2 Cal. Code Regs. § 12005(d)(2). (Motion, 8.) Cross-Defendants contend that any visiting pet was not a breach of the Lease Agreement, which provided for one pet on the premises. (Id.) Cross-Defendants also contend “[a]ny pet, visiting or owned, did not result in damage to the property that was not repaired by Cross-Defendants.” (Id.) Cross-Defendants also contend that they did not fail to notify Lorenz of damages to the residence, and as such, did not breach their duties. (Motion, 8-9.) Cross-Defendants also contend that they cleaned up after their pet and/or emotional support animal “in good faith.” (Motion, 9.) Cross-Defendants also contend that Lorenz has failed to produce any evidence showing damage caused by their failure to properly clean up. (Id.) Cross-Defendants also contend that they did not fail to water the garden and landscaping pursuant to their Lease duties, and as such did not breach their contractual obligations; they also contend the damage caused to the landscaping was due to prior tenants, arid weather, and faulty sprinkler systems. (Motion, 9-10.)

 

Cross-Defendants lastly contend Lorenz’s claims are barred by waiver, laches, and accord and satisfaction since she “accepted rent each month of the lease term,” “returned the fully security deposit,” “never informed them of estimated future damage costs, and never provided an itemized statement of repair costs.” (Motion, 10.) Cross-Defendants provide no supporting authorities for these legal conclusions, and merely make conclusory allegations.

 

In opposition, Lorenz disputed several factual claims made by Cross-Defendants. (See generally, MF 1-141.) Lorenz also contends Cross-Defendants failed to “properly use” or “maintain” the residence, as evidenced by repairs to the gate, sprinkler bib, landscaping repairs during the lease, damage done as the “the pig ate off the floors and pushed on the gate,” “a residual foul odor left after move out,” damages done as Cross-Defendants “interrupted pest control at the property causing it to be at risk for infestation,” “[e]xcessive wear and tear from an additional unapproved tenant,” as well as damages where the animal “chewed on the deck and left an odor in the premises.” (Opposition, 2-3.) Lorenz details the specific repairs which needed to be done. (Id.) Lorenz also claims that she never gave permission or authorized another occupant of the residence, or a subletting of the residence, and attests that Cross-Defendants were told “she would have to take this up with the property [management] if that occasion arose.” (Opposition, 3.) Lorenz contends “[i]ncreasing the tenancy by 50% resulted in substantially more expense as a result of the increase [sic] wear and tear and additional property management.” (Id.)

 

Lorenz also counters that the alterations made to the property were more substantive than Cross-Defendants claim, which included “screwed board and drilled screws into the fence, added 3 locks to the gate, drilled holes into the house all without prior or post notification or authority.” (Opposition, 4.) Lorenz contends that a request to inspect “with more than 24 hours of notice” was rejected by Cross-Defendants. (Id.) Lorenz also contends Cross-Defendants violated the Agreement, ¶ 12, as they “allowed their 100 pound pig to roam in the neighborhood without a leash. The pig escaped the backyard on various occasions getting loose in the neighborhood.” (Opposition, 5.) Further, Lorenz disputes Cross-Defendants claims and asserts that Cross-Defendants “had 2 dogs as well as the pig at the residence.” (Id.)

 

Lorenz also contends that Cross-Defendants “never advised her of damage of the property.” (Id.) When the damage was noted and repaired, Lorenz attests Cross-Defendants “denied causing damage resorting to threats of litigation.” (Id.)

 

Further, Lorenz also contends “that animal feces, dirt and debris was noted at the subject property during their tenancy. The pig caused pet infestation and dirt in the yard and house. The carpeting smell [sic] as a result of the pig having been inside.” (Id.) Lorenz also contends that Cross-Defendants “did not provide necessary access to the backyard on multiple occasions to cut the grass” for the gardener. (Opposition, 6.)

 

Lastly, Lorenz contends

 

“the return of the Plaintiffs’ security was not a waiver of my claims for their responsibility for the damages. Before moving out the plaintiffs filed a complaint with the Department of Fair Employment and Housing for discrimination wherein they indicated that they would file a further complaint for retaliation if the security deposit were not refunded. This security deposit was not sufficient to pay for the cost of their damage and the refund was made to avoid administrative action by the DFEH. This was before I had an opportunity to fully inspect the premises.”

(Id.)

 

In reply, Cross-Defendants contend “Lorenz had the opportunity to inspect” the premises, but “paid the full security deposit by choice as a tactic employed in her DFEH response to avoid accountability for her discrimination and retaliation against Plaintiffs.” (Reply, 6.) Cross-Defendants thus contend “Lorenz waived any claims for damages post-facto the termination of the lease.” (Reply, 7.) Cross-Defendants cite to Kern Sunset Oil Co. v. Good Roads Oil Co. (1931) 214 Cal. 435 at 440–441 (“Kern”), to argue that Lorenz waived any breaches of the contract. (Id.) “The fact that Lorenz returned the full security deposit to Cross-Defendants with no itemized statement or estimate of future repair costs should legally operate as a discharge or a complete laches defense.” (Id.) Cross-Defendants further claim that Lorenz “fails to explain how the facts differ from controlling authority to raise an issue of triable fact,” stressing that Cross-Defendants’ rent was accepted in full each month. (Id.) Cross-Defendants provide no further explanation, however. as to how the circumstances here are analogous to Kern.

 

Kern states in relevant part:

 

“The acceptance of rent by the landlord from the tenant, after the breach of a condition of the lease, with full knowledge of all the facts, is a waiver of the breach and precludes the landlord from declaring a forfeiture of the lease by reason of said breach. This is the general rule and is supported by ample authority. (15 Cal. Jur., p. 787; Miller v. Reidy, 85 Cal.App. 757; Inman v. Schecher, 86 Cal.App. 193, 198; Richards v. Silveria, 97 Cal.App. 166, 170.) The rule is also stated in Ruling Case Law as follows: ‘The most familiar instance of the waiver of the lease arises from the acceptance of rent by the landlord after condition broken, and it is a universal rule that if the landlord accepts rent from his tenant after full notice or knowledge of a breach of a covenant or condition in his lease for which a forfeiture might have been demanded, this constitutes a waiver of forfeiture which cannot afterward be asserted for that particular breach or any other breach which occurred prior to the acceptance of the rent. In other words, the acceptance by a landlord of the rents, with full knowledge of a breach in the conditions of the lease, and of all of the circumstances, is an affirmation by him that the contract of lease is still in force, and he is thereby estopped from setting up a breach in any of the conditions of the lease, and demanding a forfeiture thereof.’ (16 R.C.L., p. 1132.)”

 

(Kern Sunset Oil Co., supra, 214 Cal. at 440-441.) Further, Kern is concerned with rights to drill a portion of land, where lessees were to drill two wells per year and paid royalties to do so for eight years, where the court further found:

 

“That plaintiff waived this covenant in the lease we think there can be no question. The time in which the lessees agreed to drill and place upon production sixteen wells upon said leased premises expired on May 1, 1919, at which time, according to the contention of the plaintiff, the lessees had completed only thirteen wells. The lessees therefore at this date may have committed a clear breach of the terms of the lease. Yet after this date, and for almost five years following, the plaintiff accepted and received the regular monthly payments of royalty from the leased premises without making any complaint or objection to the default on the lessees' part. By the receipt of these payments, the plaintiff clearly and definitely recognized the existence of the lease. ‘A landlord who thus recognizes a lease as a subsisting, operative contract should not be permitted to insist upon a past forfeiture, nor be permitted to assert that the contract is no longer a subsisting lease affording to the tenant all his contractual rights thereunder. [Citing authorities.]’ Jones v. Maria, 48 Cal. App. 171.” [emphasis added]

 

(Kern Sunset Oil Co., supra, 214 Cal. at 443-444.)

 

Here, as explained in Cross-Defendants’ SAC, Lorenz and Management Defendants were proactive in their exercising of duties pursuant to the Lease Agreement to first inquire about the pig, then inquire about its status as an emotional support animal, all the while maintaining a request for Cross-Defendants to terminate their tenancy if these requests were not honored. (TAC ¶¶66, 104.) Thus, in viewing the evidence in a light most favorable to the non-moving party, the court finds Cross-Defendants have failed to meet their burden in showing a sufficient waiver, laches, or accord and satisfaction defense.

 

Further, Cross-Defendants contend “Lorenz provides no substantive responses to show a triable issue as to Cross-Defendants’ many showing of no damages.” (Reply, 7.) The court disagrees. The parties dispute the several alleged breaches of the Lease Agreement, the damages caused as a result of these alleged breaches, and provide the court with competing circumstances. Whether the animal damaged the interior of the residence and left a residual odor, whether Cross-Defendants maintained several other animals at the residence in violation of the lease provisions, and whether the Cross-Defendants maintained a roommate at the residence, as well as several other scenarios, are all factual disputes which Cross-Defendants have not shown to be without merit. Thus, in viewing the evidence in a light most favorable to the nonmoving party, the court finds several triable issues of material fact exist regarding the first cause of action, further shown by the numerous disputed factual allegations. (MF 1-141.)

 

For these reasons, Cross-Defendants’ motion is denied with respect to the first cause of action.

 

b.      Second Cause of Action: Negligence

 

Negligence consists of the following elements: (1) the defendant owed the plaintiff a duty of care, (2) the defendant breached that duty, and (3) the breach proximately caused the plaintiff’s damages or injuries.¿ (Lueras¿v. BAS Home Loan Servicing, LP¿(2013) 221 Cal.App.4th 49, 62 (Lueras).)¿ “The existence of a duty of care owed by a defendant to a plaintiff is a prerequisite to establishing a claim for negligence.”¿ (Nymark¿v. Heart Fed.¿Savs. & Loan¿Ass’n¿(1991) 231 Cal.App.3d 1089, 1095.)¿ “Whether a duty of care exists is a question of law to be determined on a case-by-case basis.”¿ (Lueras, 221 Cal.App.4th at p. 62.)¿ 

 

Here, Cross-Defendants contend the second cause of action for negligence is without merit as it seeks tort recovery “for a merely duplicated breach of contract claim.” (Motion, 11.) Cross-Defendants cite Erlich v. Menezes (1999) 21 Cal.4th 543 (“Erlich”) and Butler-Rupp v. Lourdeaux (2005) 134 Cal.App.4th 1220, 1228 (Butler-Rupp) to contend that unless the breach has caused bodily harm, tort actions for breach of contract actions should not be upheld. (Motion, 12.) Cross-Defendants then contend: (1) that the only duty alleged arises of out the Lease Agreement; (2) that “no direct physical injury to [Lorenz] is shown by the record;” (3) that “[n]othing in the record shows that Lorenz experienced serious emotional stress during Cross-Defendants’ tenancy;” (4) that “Lorenz did not suffer any recoverable damages;” (5) that the economic loss rule bars Lorenz’s claims; (6) that Cross-Defendants’ conduct was not the proximate cause of Lorenz’s miscarriage; and (7) Lorenz’s claims are barred by public policy, waiver, and a failure to mitigate damages. (Motion, 11-16.)

 

In opposition, Lorenz indicates she suffered “[a]nxiety, stress, anguish, nervousness, sleeplessness, headaches, migraines, pain and tightness to the head, neck and back, stomach pain, loss of appetite, difficulty focusing, chest tightness, depression, lack of focus and being disconnected from engagements and work” and attests she “suffered a miscarriage due to physical and emotional pain the tenants continuously inflicted on my unborn child and me during my pregnancy. I have been diagnosed with depression and anxiety disorders.” (Lorenz Decl. 5:17-24.) Lorenz also attests her treating physician, Dr. Conrad, indicated “the stress I [e]ndured was probably a contributing factor in my pregnancy loss and noting stress which I was under in 2020.” (Lorenz Decl. 6:7-9, Exh. D.) Here, Lorenz also points to Cross-Defendants’ unsuccessful demurrer of the second cause of action as evincing of the negligence claim having merit. (Opposition, 7.) As the relevant inquiry at the demurrer stage differs greatly, the court disregards this argument.

 

Lorenz then attests Cross-Defendants owed a duty “to maintain and repair the Subject Property and to surrender possession in the same condition it was in at the beginning of the tenancy.” (Id.) Lorenz contends the breaching of this duty caused her physical injury, as described above. (Id.) Lorenz attests “the stress caused by the [Cross-Defendants] caused a hormone leading to the miscarriage.” (Opposition, 8.)

 

In Reply, Cross-Defendants contend “the alleged contractual breaches are indistinguishable from any breach of a legal duty concerning maintenance of the property,” and as such, “no triable issue exists as to damages.” (Reply, 5-6.) Cross-Defendants further contend the “economic loss rule bars recovery of Lorenz’s negligence claim because any damages are contemplated by the terms of the lease agreement.” (Id.)

 

The Erlich Court ruled in relevant part:

 

“it is sufficient to note that more than mere negligence has been involved in each case where tort damages have been permitted. The benefits of broad compensation must be balanced against the burdens on commercial stability. ‘[C]ourts should be careful to apply tort remedies only when the conduct in question is so clear in its deviation from socially useful business practices that the effect of enforcing such tort duties will be ... to aid rather than discourage commerce.” (Freeman & Mills, supra, 11 Cal.4th at p. 109 (conc. and dis. opn. of Mosk, J.).)

 

...

 

‘No California case has allowed recovery for emotional distress arising solely out of property damage’ (Cooper v. Superior Court (1984) 153 Cal.App.3d 1008, 1012,); moreover, a preexisting contractual relationship, without more, will not support a recovery for mental suffering where the defendant's tortious conduct has resulted only in economic injury to the plaintiff. (Smith v. Superior Court (1992) 10 Cal.App.4th 1033, 1040, fn. 1, 13; Mercado v. Leong (1996) 43 Cal.App.4th 317, 324, emotional distress damages are unlikely when the interests affected are merely economic]; Camenisch v. Superior Court (1996) 44 Cal.App.4th 1689, 1691(Camenisch ) [emotional distress damages are not recoverable when attorney malpractice leads only to economic loss].)

 

...

it reiterates that ‘unless the defendant has assumed a duty to plaintiff in which the emotional condition of the plaintiff is an object, recovery is available only if the emotional distress arises out of the defendant's breach of some other legal duty and the emotional distress is proximately caused by [breach of the independent duty]. Even then, with rare exceptions, a breach of the duty must threaten physical injury, not simply damage to property or financial interests. [Citations.]’

 

(Erlich, supra, 21 Cal.4th at 554-6; citing Potter v. Firestone Tire & Rubber Co. (1993) 6 Cal.4th 965.)

 

The Butler-Rupp finding provides further elaboration:

 

“The question therefore becomes whether the jury's finding of negligence can support an award of damages for emotional distress on the present record. The Erlich decision also addresses this issue. The Erlich court observed emotional distress damages are not “ ‘available in every case in which there is an independent cause of action founded upon negligence.’ [Citation.]” (Erlich v. Menezes, supra, 21 Cal.4th 543, 554.) Such damages have generally been allowed where the defendant's conduct caused physical injury. For example, Potter v. Firestone Tire & Rubber Co. (1993) 6 Cal.4th 965, affirmed a judgment of damages where the plaintiffs suffered from prolonged exposure to a carcinogen. But in the absence of physical injury, the courts have never allowed recovery of damages for emotional distress arising solely from property damage or economic injury to the plaintiff. The injury suffered by the Erlich plaintiffs—the negligent construction of their house—did not cause physical injury and “derive[d] from an inherently economic concern.” [emphasis added]

(Butler-Rupp v. Lourdeaux, supra, 134 Cal.App.4th at 1227–1228.)

 

Thus, the relevant inquiry the court asks here is whether there are no triable issues of material fact regarding a physical injury which Cross-Defendants proximately caused. First, the court notes that the damages alleged by Lorenz in her second cause of action differ from those alleged in the first cause of action, namely Lorenz here alleges she suffered “damages including but not limited to emotional and physical distress which included the loss of an unborn child, and loss revenue [sic].” (TACC ¶15.) Thus, the alleged injuries are not merely economic, but Lorenz explicitly alleges Cross-Defendants caused physical injuries as a result of their “actions and omissions.” (TACC ¶16.)

 

Second, the Butler-Rupp contemplated the influence of the economic loss rule and explained that damages not for “purely economic loss” can still be award. (Butler-Rupp, supra, 134 Cal.App.4th at 1229.) Precedent has also found duty in emotional distress cases by looking at seven traditional factors: “(1) the foreseeability of harm to the plaintiff, (2) the degree of certainty that plaintiff suffered injury, (3) the closeness of the connection between the conduct and the injury suffered, (4) the moral blame attached to defendant's conduct, (5) the policy of preventing future harm, (6) the extent of the burden to the defendant, and (7) the consequences to the community of imposing a duty to exercise care with resulting liability for breach, and the availability, cost, and prevalence of insurance for the risk involved,” where foreseeability is of limited use. (Lawson v. Management Activities, Inc. (1999) 69 Cal.App.4th 652, 657.)

 

Here, viewing the evidence in a light most favorable to the nonmoving party, triable issues of material fact remain as to the closeness of connection between Cross-Defendants’ conduct and Lorenz’s injuries, the extent of Cross-Defendants’ burden for Lorenz’s physical injuries, and the degree of certainty that Lorenz suffered her physical injuries as a result of Cross-Defendants’ conduct. 

 

For these reasons, Cross-Defendants’ motion is denied as to the second cause of action.

 

c.       Fourth Cause of Action: Negligent Infliction of Emotional Distress

 

Negligent infliction of emotional distress (“NIED”) is not an independent tort; it is merely convenient terminology descriptive of the context in which the negligence occurred.¿ (Long v. PKS, Inc.¿(1993) 12 Cal.App.4th 1293, 1297.)¿ As with any cause of action for negligence, the traditional elements of duty, breach of duty, causation and damages apply.¿ (Ess¿v. Eskaton Props.¿(2002) 97 Cal.App.4th 120, 126.)¿ Klein v. Children’s Hospital Medical Center (1996) 46 Cal.App.4th 889, 894 (Klein) holds that “[w]hether plaintiffs can recover damages for NIED is dependent upon traditional tort analysis” for a negligence claim. Thus, Klein merely stands for the proposition that an NIED claim carries similar pleading standards to that of a “negligence” claim, not that an NIED claim may not be pled.

 

Here, Cross-Defendants again emphasize that NIED is not an independent tort. (Motion, 18.) Cross-Defendants also repeat analogous contentions from the second cause of action. (Motion, 18-20.)

Thus, as the court has found triable issues of material fact to exist as to the second cause of action, the court also therefore denies Cross-Defendants’ motion as to the fourth cause of action.

 

d.      Fifth Issue: Management Defendants’ 26th Affirmative Defense of Agent Immunity Rule

 

“It is . . . well established that corporate agents and employees acting for and on behalf of a corporation cannot be held liable for inducing a breach of the corporation’s contract.”  (Shoemaker v. Myers (1990) 52 Cal.3d 1, 24.)  “[T]he tort cause of action for interference with contract does not lie against a party to the contract.”  (Applied Equipment Corp. v. Litton Saudi Arabia Ltd. (1994) 7 Cal.4th 503, 514.)  “[T]he agent’s immunity rule has no direct applicability to a claim for interference with contract rights.  The rule is that duly acting agents and employees cannot be held liable for conspiring with their own principals.”  (Mintz v. Blue Cross of California (2009) 172 Cal.App.4th 1594, 1605.)  “[T]he rule, on its face, applies only to claims of conspiracy to commit a tort of violate a statute.”  (Id.) “[T]here is no financial advantage exception to the rule that a corporate agent cannot be liable for interfering with its principal’s contract.”  (Id. at 1606.)  “An agency is proved by evidence that the person for whom the work was performed had the right to control the activities of the alleged agent.”  (van’t Rood v. County of Santa Clara (2003) 113 Cal.App.4th 549, 572.) 

 

Cross-Defendants contend that Management Defendants can be held personally liable in tort, “because transaction between rental agent and landlord was clearly intended to affect tenants and because harm would be foreseeable to tenants if rental agent did not properly perform his duty.” (Motion, 20.)

 

In opposition, Management Defendants first contend that the listed agent, pursuant to the Lease Agreement between the parties, was Defendant Pres. Now, where Defendants Herrera and Plotner worked. (Opposition, 2.) Additionally, Management Defendants point to the Property Management Agreement signed between Lorenz and Management Defendants, and its Indemnity Provision which states:

 

Paragraph 4(B) of the Property Management Agreement, provides that the Owner shall:

Indemnify, defend and hold harmless Property Manager, and all persons in Property Manager's firm, as permitted by law, from all costs, expenses, suits, liabilities, damages, attorney fees and claims of every type, including but not limited to those arising out of injury or death of any person, or damage to any real or personal property of any person, including Owner, (i) for any repairs performed by Owner or by others hired directly by Owner; (ii) for those acts relating to the management, leasing, rental, security deposits or operation of the Property by Property Manager, or any person in Property Manager's firm, or the performance or exercise of any of the duties, powers or authorities granted to Property Manager; or (iii) from any incorrect or incomplete information supplied by Owner, or from any material facts that Owner knows but fails to disclose including dangerous or hidden conditions on the Premises.

 

 (Opposition, 3-4; Herrera Decl., ¶ 14; Compendium, Exh. C.) Management Defendants further contend the agent immunity rule applies here as “they were merely acting as an agent of the Owner and/or employee of Pres. Now Inc., a management company hired by the Owner.” (Opposition, 8.) Thus, Management Defendants contend they were acting in their official capacity, and not “for their individual advantage,” and provide supporting authority for their contentions. (Id.)

 

In reply, Cross-Defendants contend “discrimination, retaliation, civil rights violations, interference with contractual relations and intentional infliction of emotional distress (even as mere allegations) fall outside the scope of Property Management Defendants’ official duties as rental agents. Indeed, the Property Management Defendants owed an affirmative independent legal duty to Plaintiffs as tenants of the property not to permit discrimination, retaliation, civil rights violations, interference, and intentional infliction of emotional distress.” (Reply, 3-4.) Thus, Cross-Defendants contend that liability should be imposed, and the agent immunity rule should not be applied, as to Management Defendants because they acted outside the scope of their actions as agents of Lorenz. (Reply, 3-5.) Cross-Defendants further request summary adjudication stating, “[w]hether an affirmative defense of agent immunity applies to the torts committed by the property management agents of a landlord is a matter of law.” (Reply, 2.) Thus, Cross-Defendants contend it is a matter of law that the agent immunity rule cannot provide an affirmative defense, since Management Defendants acted outside the scope of their official duties. (Reply, 2-5.)

 

However, while the applicability of the agent immunity rule is normally a matter of law, there remain several triable issues of material fact as to whether Management Defendants acted outside the scope of their official duties as agents to Lorenz, thereby nullifying the agent immunity affirmative defense. Thus, Cross-Defendants have failed to show that Management Defendants’ affirmative defense to be void of merit. 

 

For these reasons, Cross-Defendants’ motion is denied as to the 26th Affirmative Defense.  

 

Conclusion 

 

Cross-Defendants’ motion is denied. Cross-Defendants are to give notice.