Judge: Gary I. Micon, Case: 23CHCV01449, Date: 2024-04-16 Tentative Ruling



Case Number: 23CHCV01449    Hearing Date: April 16, 2024    Dept: F43

Dept. F43

Date: 4-16-24

Case #23CHCV01449, Jacob Alvarado vs. American Honda Motor Co., Inc.

Trial Date: N/A

 

DEMURRER WITH MOTION TO STRIKE

 

MOVING PARTY: Defendant American Honda Motor Co., Inc.

RESPONDING PARTY: Plaintiff Jacob Alvarado

 

RELIEF REQUESTED

Demurrer to the Complaint

·         2nd Cause of Action: Fraudulent Inducement – Concealment

 

Motion to Strike

·         Prayer for Punitive Damages [Comp., p. 27, line 9, subpart 6]

 

RULING: Demurrer is sustained with leave to amend; motion to strike granted

 

SUMMARY OF ACTION

On March 13, 2022, Plaintiff Jacob Alvarado (Plaintiff) purchased a new 2022 Honda Insight. (Comp., 8.) Plaintiff received a New Vehicle Limited Warranty in connection with the purchase of the vehicle from Defendant American Honda Motor Co., Inc. (Defendant). (Comp., 9.) Plaintiff alleges that the vehicle was equipped with a defective computerized driver-assistance safety system called “Honda Sensing”. (Comp., 11.) Plaintiff alleges that Defendant failed to disclose that normal, everyday driving conditions can cause problems with Honda Sensing. (Comp., ¶¶ 20-21.) Plaintiff further alleges that Honda knew or should have known about the defects with Honda Sensing, yet Honda sold the vehicles anyways. (Comp., ¶¶ 22-26.)

 

Plaintiff alleges that Defendant knew of the Honda Sensing defect since at least 2016 and knowingly sold a dangerously defective vehicle to Plaintiff. (Comp., ¶¶ 27-64.) Plaintiff further alleges that Defendant did not disclose and has actively concealed the Honda Sensing defect (Comp., ¶¶ 71-83.) Plaintiff also alleges that he would not have purchased the vehicle had he known about the defect (Comp., ¶ 80.) Further, Plaintiff alleges that Defendant markets its vehicle as particularly reliable when compared to the competition. (Comp., ¶ 81.) Finally, Plaintiff alleges that Defendant and its representatives at the dealership where Plaintiff bought his vehicle did not disclose the defect to Plaintiff. (Comp., ¶ 87.)

 

On May 16, 2023, Plaintiff filed his complaint with two causes of action for (1) Violation of Song-Beverly Act – Breach of Express Warranty; and (2) Fraudulent Inducement – Concealment.

 

Defendant filed its demurer with motion to strike on June 21, 2023. Plaintiff filed his opposition to Defendant’s demurrer and motion to strike on January 2, 2024. Defendant filed its reply on January 16, 2024.

 

Plaintiff’s Request for Judicial Notice: Pursuant to Evidence Code §§ 452(d) and 453, Plaintiff requests that the Court take judicial notice of a Second Amended Complaint filed in a lemon law case in Alameda County. Defendant opposes Plaintiff’s request on the basis that Plaintiff did not acknowledge that review is pending in that case. Defendant also argues that the case can be used for persuasive value only. The Court denies Plaintiff’s request for judicial notice.

 

ANALYSIS

Defendant brings a demurrer to the Second Cause of Action for Fraudulent Inducement – Concealment. Defendant contends the challenged cause of action fails to state facts sufficient to constitute a cause of action against it.

 

A demurrer is an objection to a pleading, the grounds for which are apparent from either the face of the complaint or a matter of which the court may take judicial notice. (CCP § 430.30(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.” (CCP § 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.)

 

A fraud cause of action requires a Plaintiff to plead and prove: “(a) [a] misrepresentation (false representation, concealment, or nondisclosure); (b) knowledge of falsity (or “scienter”); (c) intent to defraud, i.e., to induce reliance; (d) justifiable reliance; and (e) resulting damage.” (Lazar v. Superior Court (1996) 12 Cal 4th 631, 638.) Fraud causes of action must be pled with specificity. “…This particularity requirement necessitates pleading facts which ‘show how, when, where, to whom and by what means the representations were tendered.’” (Stansfield v. Starkey (1990) 220 Cal.App.3d 59, 73, quoting Hills Trans. Co. v. Southwest (1968) 266 Cal.App.2d 702, 707.)

 

Fraud claims against a corporation must “allege the names of the persons who made the allegedly fraudulent 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.)

 

Plaintiff’s complaint alleges that Defendant and its agents “actively concealed the nature and existence of the Honda Sensing Defect from Plaintiff at the time of purchase, repair, and thereafter.” (Comp., ¶ 71.) However, his complaint does not allege that any specific misrepresentations were made to him about the Honda Sensing system.

 

Plaintiff’s allegations are not enough to satisfy the pleading requirements for fraud. While Plaintiff alleges that the Honda Sensing defect was not disclosed to him, he does not plead any facts indicating that people with whom Plaintiff spoke at the dealership had knowledge of or should have had knowledge of the defect. He also has not pled whether, if the representatives at the dealership did have knowledge of the defect, they intended to defraud Plaintiff.

 

Plaintiff has also failed to plead the requisite specificity required for fraud actions. He has not pled how, when, where, and by what means the misrepresentations (or nondisclosures, in this case) were tendered. Without the specific details regarding the misrepresentations and nondisclosure, Plaintiff cannot maintain a cause of action for fraud. Plaintiff was also required to allege the names of persons who made the fraudulent statement, their authority to speak, and what they said. Plaintiff did not do so.

 

Furthermore, Plaintiff primarily makes conclusory allegations about the misrepresentations made by Defendant. (See Comp., ¶¶ 23, 44.) Conclusory allegations are not sufficient for fraud causes of action.

 

Plaintiff argues in his opposition that he sufficiently alleged that Defendant had a duty to disclose the defect. The duty to disclose arises in four ways: “(1) when the defendant is in a fiduciary relationship with the plaintiff, (2) when the defendant had exclusive knowledge of material facts not known to the plaintiff, (3) when the defendant actively conceals a material fact from the plaintiff and (4) when the defendant makes partial representations but also suppresses some material facts.” (Heliotis v. Schuman (1986) 181 Cal.App.3d 646, 651, quoting 4 Witkin, Summary of Cal. Law (8th ed. 1974) Torts, §§ 459-464.)

 

Plaintiff argues that Defendant had a duty to disclose the concealed facts because it had exclusive knowledge of material facts that were not known to Plaintiff about the defect. While Plaintiff’s complaint does, in fact, allege that Defendant had this knowledge (See Comp., ¶¶ 23-26, 28, 35, 37-43, et al.), that is not sufficient by itself to constitute allegations of fraud. Plaintiff also argues that he alleges specific facts sufficient to demonstrate concealment. Once again, that is not sufficient to maintain a fraud cause of action without the requisite specificity.

 

Next, Plaintiff argues that his complaint contains the specificity required of fraud actions. He argues that in situations where the actual person who authorized the false documents is not known to Plaintiff, then he is not required to identify the person because “[t]he requirement of specificity is relaxed when the allegations indicate that the defendant must necessarily possess full information concerning the facts of the controversy or when the facts lie more in the knowledge of the opposite party.” (Tarmann v. State Farm Mutual Auto-Mobile Ins. Co. (1992) 2 Cal.App.4th 153, 158.) Plaintiff argues that his allegations that he viewed promotional materials and spoke to agents at the dealership are sufficient for his fraudulent concealment cause of action. However, Plaintiff does not allege that these materials said anything about the Honda Sensing system, or that he relied on any particular representations made about the system. Without reliance, Plaintiff cannot maintain a cause of action for fraud on this issue.

 

Defendant also argues that Plaintiff’s cause of action for fraudulent inducement would be barred because of the economic loss rule. Despite Defendant’s arguments to the contrary, a fraudulent inducement cause of action would not be barred by the economic loss rule. It is a long-standing principle in California law that a party may recover for both breach of contract and fraud. (See Lazar v. Superior Court (1996) 12 Cal.4th 631, 645; see also Freeman & Mills, Inc. v. Belcher Oil Co. (1995) 11 Cal.4th 85, 108 (Plaintiffs permitted to recover exemplary damages in cases where the breached contract was induced through promissory fraud).) “Although punitive damages may not be awarded where defendant merely breaches a contract…such damages may be awarded where defendant fraudulently induces Plaintiffs to enter into a contract. Fraudulent inducement to enter into a contract constitutes a tort.” (Kuchta v. Allied Builders Corp. (1971) 21 Cal.App.3d 541, 549; see also Walker v. Signal Companies, Inc. (1978) 84 Cal.App.3d 982, 996.)

 

While Plaintiff has not alleged sufficient allegations to maintain a cause of action for fraudulent inducement, pleading that cause of action is not barred by the economic loss rule.

 

Defendant’s demurrer to Plaintiff’s Second Cause of Action is sustained with leave to amend

 

Motion to Strike

Defendant has moved to strike Plaintiff’s request for punitive damages on the basis that Plaintiff has not sufficiently pled that Defendant acted with oppression, fraud, or malice.

 

This Court may strike from the complaint any irrelevant, false, or improper matter. Under CCP § 435, “[a]ny party, within the time allowed to respond to a pleading may serve and file a notice of motion to strike the whole or any part thereof.” Under CCP § 436(a), “[t]he court may, upon a motion made pursuant to Section 435, or at any time in its discretion, and upon terms it deems proper . . . [s]trike out any irrelevant, false, or improper matter inserted in any pleading.”

 

Punitive damages are governed by Civ. Code § 3294: “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.” (Civ. Code § 3294(a).)

 

No punitive damages are available under the Song-Beverly Act. Recovery under that statute is limited to a refund of the purchase price paid and payable (or replacement of the subject vehicle), plus a civil penalty, where applicable, not to exceed two times Plaintiff’s actual damages (Civ. Code § 1794.)

 

The Court has sustained Defendant’s demurrer to Plaintiff’s fraudulent inducement cause of action. Because punitive damages are not allowable under the Song-Beverly Act, punitive damages are not available for Plaintiff’s other cause of action. If Plaintiff is able to sufficiently amend his fraudulent cause of action, then punitive damages may be requested. For now, Defendant’s motion to strike Plaintiff’s request for punitive damages is granted.

 

CONCLUSION

Defendant’s demurrer to Plaintiff’s Second Cause of Action is sustained with leave to amend.

 

Defendant’s motion to strike Plaintiff’s request for punitive damages is granted.

 

Plaintiff is given 30 days leave to amend.

 

Moving party to give notice to all parties.