Judge: Gary I. Micon, Case: 22CHCV00040, Date: 2025-04-25 Tentative Ruling

Case Number: 22CHCV00040    Hearing Date: April 25, 2025    Dept: F43

Dept. F43

Date: 04-25-25

Case # 22CHCV00040, Coates v. Interinsurance Exchange of the Automobile Club

Trial Date: None set.

 

DEMURRER

 

MOVING PARTY: Defendant Interinsurance Exchange of the Automobile Club

RESPONDING PARTY: No response has been filed.

 

RELIEF REQUESTED

Order sustaining demurrer to the complaint’s First and Second Causes of Action.

 

RULING: Demurrer to the complaint’s First and Second Causes of Action is sustained with leave to amend.

 

SUMMARY OF ACTION

On January 18, 2022, plaintiff James Coates (Plaintiff) filed a complaint against defendant Interinsurance Exchange of the Automobile Club (Defendant), alleging breach of contract and bad faith causes of action.  Plaintiff seeks compensatory damages and punitive damages.  Plaintiff is self-represented.

 

On March 24, 2025, Defendant filed a demurrer alleging that the complaint is uncertain and fails to allege sufficient facts to constitute causes of action.  No opposition has been filed.

 

MEET AND CONFER

Before filing a demurrer, the parties must meet and confer “in person, by telephone, or by video conference.”  (Code Civ. Proc., § 430.41, subd. (a).)  The moving party must file and serve a meet and confer declaration stating either: (1) the means by which the parties met and conferred, that the parties did not reach an agreement resolving the issues raised in the demurrer; or (2) that the party who filed the pleading subject to the demurrer failed to respond to the meet and confer request or failed to meet and confer in good faith.  (Code Civ. Proc., §§ 430.41, subd. (a)(3).)  On February 19, 2025, defense counsel left a voicemail with Plaintiff requesting a call back to meet and confer about the demurrer.  (Declaration of Tina M. Bhatia, ¶ 2.)  On March 20, 2025, defense counsel emailed Plaintiff explaining the bases for the demurrer.  (Bhatia Dec., ¶ 3, Exh. A.)  Plaintiff never responded by phone or email.  (Bhatia Dec., ¶ 4.)

 

SUMMARY OF ARGUMENTS

Defendant contends that Plaintiff fails to plead the existence of a contract, by its terms or legal effect, or to set forth the dates on which the alleged insurance agreement was in force.  The complaint also fails to allege the date of the underlying auto accident.  The complaint is unclear as to whether the second cause of action is a common count or a bad faith claims handling cause of action.  Additionally, actions based on an express contract may not be pleaded by common count if Plaintiff seeks either damages or specific performance.

 

Plaintiff does not oppose.

 

ANALYSIS

 

Legal Standard

A¿ party may respond to a pleading against it by demurrer based on any single or combination of eight enumerated grounds, including¿that¿“the pleading does not state facts sufficient to constitute a cause of action” and is uncertain, meaning “ambiguous and unintelligible.”  (Code Civ. Proc., § 430.10, subds. (e), (f).)  The grounds for demurring must be apparent from either the face of the complaint or a matter of which the court may take judicial notice.  (Code Civ. Proc., § 430.30, subd. (a); see also Blank v. Kirwan (1985) 39 Cal.3d 311, 318.)  The purpose of a demurrer is to challenge the sufficiency of a pleading “by raising questions of law.”  (Postley v. Harvey (1984) 153 Cal.App.3d 280, 286.)  “In the construction of a pleading, for the purpose of determining its effect, its allegations must be liberally construed, with a view to substantial justice between the parties.”  (Code Civ. Proc., § 452.)  The court “treat[s] the demurrer as admitting all material facts properly pleaded, but not contentions, deductions or conclusions of fact or law[.]”  (Berkley v. Dowds (2007) 152 Cal.App.4th 518, 525.)  In applying these standards, the court liberally construes the complaint to determine whether a cause of action has been stated.  (Picton v. Anderson Union High School Dist. (1996) 50 Cal.App.4th 726, 733.)

 

 

            Defendant’s demurrer is timely.

If parties are unable to meet and confer at least five (5) days before the responsive pleading is due, section 430.41 grants the demurring party an automatic 30-day extension within which to file a responsive pleading.  (Code Civ. Proc., § 430.41, subd. (a)(2).)  The demurring party must file and serve on or before the date on which a demurrer would be due, a declaration stating reasons for failing to meet and confer.  (Ibid.)  The 30-day extension commences on the date the responsive pleading was originally due.  (Ibid.)

 

On January 21, 2025, Plaintiff personally served the summons and complaint on Defendant.  The original deadline for Defendant to file a responsive pleading was Thursday, February 20, 2025.  On February 20, 2025, Defendant filed and served a declaration to automatically extend the time to file a responsive pleading by 30 days pursuant to Civil Procedure section 430.41.  Plaintiff does not oppose the declaration.  Therefore, the time to file a responsive pleading was extended to March 24, 2025, and Defendant timely filed its demurrer that same day.

 

            First Cause of Action: Breach of Written Contract

Defendant demurs to the First Cause of Action because the complaint is uncertain and fails to allege the existence of a contract.

 

To plead breach of contract, a complaint must allege facts showing (1) the existence of a contract, (2) plaintiff’s performance or excuse for nonperformance, (3) defendant’s breach, and (4) resulting damages to plaintiff.  (Oasis West Realty, LLC v. Goldman (2011) 51 Cal.4th 811, 821;  Aton Center, Inc. v. United Healthcare Ins. Co. (2023) 93 Cal.App.5th 1214, 1230.)

 

“In an action based on a written contract, a plaintiff may plead the legal effect of the contract rather than its precise language.”  (Construction Protective Services, Inc. v. TIG Specialty Ins. Co. (2002) 29 Cal.4th 189, 198-99.  But see Harris v. Rudin, Richman & Appel (1999) 74 Cal.App.4th 299, 307 [requiring plaintiff to attach a copy of the contract or to set out the terms verbatim in the body of the complaint].)  Pleading contracts by legal effect involves alleging the relevant terms in substance.  (McKell v. Washington Mutual, Inc. (2006) 142 Cal.App.4th 1457, 1489.)

 

The complaint fails to plead the existence of a written contract.  Plaintiff does not attach a copy of the alleged contract or allege the contract’s terms and legal effect.  The complaint alleges that Defendant entered into a contract (Compl., ¶ 7.a.), that defendant breached the contract (Compl., ¶ 8.), and that Plaintiff seeks $15,000.00 in damages and 10 percent interest per year since the alleged breach.  (Compl., Attachment 9.)  These facts are insufficient to establish the terms of the contract, the contract’s legal effect, or Plaintiff’s performance or excuse from performance.  The complaint is also uncertain because Plaintiff does not allege what conduct caused the alleged breach.

 

Therefore, Defendant’s demurrer to the First Cause of Action for breach of contract is sustained.

 

            Second Cause of Action: Bad Faith Claims Handling

Next, Defendant demurs to the second cause of action for being uncertain and failing to state sufficient facts to constitute a cause of action.  Defendant contends that the complaint is unclear concerning whether Plaintiff pleads a common count or a bad faith handling cause of action.  Plaintiff cannot plead both a common count and a breach contract.

 

Based on the complaint filed in the case docket, Plaintiff does not plead any common counts.  Therefore, this argument fails.

 

The complaint does allege a “Bad Faith” cause of action.  (Compl., ¶ 8.)

 

The elements of a bad faith claims handling cause of action are: (1) that the insurer has withheld benefits due under a policy, and 92) that the withholding was unreasonable or without proper cause.  (Major v. Western Home Ins. Co. (2009) 169 Cal.App.4th 1197, 1209.)  Conduct constituting bad faith handling includes denying benefits due, paying less than due, and unreasonably delayed payments due.  (Ibid.)

 

Plaintiff fails to allege an insurance policy or agreement under which benefits were due.  Plaintiff also fails to allege Defendant unreasonably denied or withheld any benefits.  “Attachment 9” states that Plaintiff seeks $15,000.00 in punitive damages and $30,000.00 in emotional distress damages.  (Compl., Attachment 9.)  However, Plaintiff does not state what conduct justifies these damages.  Without further facts alleging an insurance policy or agreement, Plaintiff fails to allege a bad faith claims handling cause of action.

 

Therefore, Defendant’s demurrer to the Second Cause of Action is sustained.

 

            Leave to Amend

Defendant’s demurrer references several facts (insurance agreement) and exhibits that do not appear anywhere in the complaint.  (See Demurrer, p. 3:8-21 [discussing an “Intro Letter” and a check issued by Defendant].)  The only exhibit attached to the complaint is a document titled “Monetary Compensation” which states the damages and fees Plaintiff seeks to recover.  The complaint references other attachments (2A, 2b, 4A, 4b, 5A, and 5b), but it appears that Plaintiff did not file these attachments with the complaint.  (Compl., ¶ 11.)

 

Because these alleged facts and attachments suggest that Plaintiff may be able to remedy the deficiencies in his causes of action, the court grants Plaintiff leave to file an amended complaint.

 

CONCLUSION

Defendant Interinsurance Exchange of the Automobile Club’s demurrer to the complaint’s First and Second Causes of Action is sustained with leave to amend.

 

Plaintiff may file an amended complaint within thirty (30) days of this order.

 

Defendant Interinsurance Exchange of the Automobile Club to give notice.





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