Judge: Gary I. Micon, Case: 23CHCV02348, Date: 2024-05-03 Tentative Ruling

Case Number: 23CHCV02348    Hearing Date: May 3, 2024    Dept: F43

Dept. F43

Date: 5-3-24

Case #23CHCV02348, William Holmquist vs. Ford Motor Company, et al.

Trial Date: N/A

 

DEMURRER TO FIRST AMENDED COMPLAINT WITH MOTION TO STRIKE

 

MOVING PARTY: Defendant Ford Motor Company

RESPONDING PARTY: Plaintiff William Holmquist

 

RELIEF REQUESTED

Demurrer to the Complaint

·         3rd Cause of Action: Violation of Subdivision (A)(3) of Civil Code Section 1793.2

·         5th Cause of Action: Fraudulent Inducement – Concealment

 

Motion to Strike

·         Punitive damages request and allegations (Page 14, lines 5-7; Page 18, line 10)

 

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

 

SUMMARY OF ACTION

On July 15, 2019, Plaintiff William Holmquist (Plaintiff) purchased a 2019 Ford F-150. (FAC, 9.) Plaintiff received various warranties in connection with the purchase of the vehicle from Defendant Ford Motor Company (Defendant). (FAC, ¶ 9-10.) Plaintiff alleges that there were transmission defects, electrical defects, and other non-conformities with the vehicle. (FAC, 14.)

 

Plaintiff alleges that Defendant knew of the vehicle’s transmission defects prior to Plaintiff purchasing the vehicle. (FAC, 29.) Plaintiff alleges that the Transmission Defect makes the vehicle unsafe. (FAC, ¶ 41.) Plaintiff alleges that Defendant issued several service bulletins related to the Transmission Defect. (FAC, ¶ 31.)

 

On August 4, 2023, Plaintiff filed his complaint with six causes of action. Defendant’s demurrer to the Third and Fifth Causes of Action of Plaintiff’s initial complaint was sustained with leave to amend on February 1, 2024. Plaintiff filed his First Amended Complaint (FAC) on March 1, 2024. Defendant filed a demurrer to the Third and Fifth Causes of Action of the FAC with a Motion to Strike on March 28, 2024. Plaintiff opposes Defendant’s demurrer and motion to strike.

 

ANALYSIS

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.)

 

Third Cause of Action for Violation of Civil Code Section 1793.2(a)(3)

Defendant brings a demurrer to the Third Cause of Action for Violation of Subdivision (A)(3) of Civil Code Section 1793.2. Defendant argues that this cause of action fails to state sufficient facts alleging a failure to provide sufficient service literature and replacement parts.

 

In cases where statutory remedies are invoked, “[f]acts, not conclusions, must be pleaded,” and the facts “must be pleaded with particularity.” (Carter v. Prime Healthcare Paradise Valley LLC (2011) 198 Cal.App.4th 396, 410.) The section at issue in this cause of action requires a manufacturer to “[m]ake available to authorized service and repair facilities sufficient service literature and replacement parts to effect repairs during the express warranty period.” (Civ. Code § 1793.2(a)(3).)

 

Plaintiff’s Third Causes of Action remains largely unchanged from the first iteration of Plaintiff’s complaint. It does not plead any facts that would indicate that Ford failed to provide sufficient service literature and replacement parts to its authorized repair facilities. While Plaintiff added some paragraphs regarding the efforts taken to repair the vehicle (FAC, ¶¶ 25-28, 38-40), these allegations do not allege that Defendant failed to provide sufficient service literature or replacement parts to the service and repair facilities. Additionally, under the cause of action itself, Plaintiff still just recites the statutory language verbatim in his complaint. (FAC, ¶ 55.) This does not meet the pleading standard requiring that facts be pleaded with particularly. Plaintiff also did not add any facts under this cause of action after being given leave to amend.

 

Once again, Plaintiff argues in his opposition that inferences may be drawn from what he has pled, but he has not pled any facts from which inferences may be drawn. He has only pled a recitation of the statute. Plaintiff also argues that he does not have to plead what specific parts or literature Defendant withheld because Defendant would have this information. However, this would fall short of the notice pleading standard. Without knowing what parts or literature Plaintiff is alleging were withheld, Defendant cannot address Plaintiff’s claims. Plaintiff has also not pled how he was damaged by the alleged withholding.

 

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

 

Fifth Cause of Action for Fraudulent Inducement - Concealment

Defendant also brings a demurrer for the Fifth Cause of Action for Fraudulent Inducement – Concealment. Defendant contends the challenged cause of action fails to state sufficient facts alleging fraud.

 

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.)

 

Plaintiff’s complaint alleges that Defendant allowed the vehicle to be sold without disclosing the transmission defect. However, his complaint does not allege that any specific misrepresentations were made to him about the transmission, or that he relied on any communications from Defendant about the transmission. (FAC, ¶¶ 64-74.) He also does not include any statements from Defendant or its representatives that he would have relied upon to buy the vehicle. Plaintiff’s complaint also does not allege where he bought the vehicle.

 

Plaintiff’s allegations are not enough to satisfy the pleading requirements for fraud. While Plaintiff alleges that the transmission defect was not disclosed to him, he does not plead any facts indicating he spoke with anyone from Ford Motor Company about the transmission. “The requirement of specificity in a fraud action against a corporation requires the plaintiff to 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 has not pled this information. He also has not pled whether there was any intent to defraud him.

 

Plaintiff has failed to plead the requisite specificity required for fraud causes of action. He has not pled how, when, where, and by what means the alleged misrepresentations (or nondisclosures, in this case) were tendered. Without the specific details regarding the misrepresentations and/or nondisclosure, Plaintiff cannot maintain a cause of action for fraud.

 

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

 

Motion to Strike

Defendant has moved to strike Plaintiff’s request for punitive damages and related allegations.

 

A 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.” Under CCP § 436(b), the court may “[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.”

 

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).) 

 

To state a prima facie claim for punitive damages, a complaint must set forth the elements as stated in Civ. Code § 3294. (Coll. Hosp., Inc. v. Superior Court (1994) 8 Cal.4th 704, 721.) “Malice is defined in the statute as conduct intended by the defendant to cause injury to the plaintiff or despicable conduct which is carried on by the defendant with a willful and conscious disregard of the rights or safety of others.” (Id. at 725.) Oppression is “despicable conduct that subjects a person to cruel and unjust hardship in conscious disregard of that person’s rights.” (Civ. Code § 3294(c)(2).) Fraud is defined as “an intentional misrepresentation, deceit, or concealment of a material fact known to the defendant with the intention on the part of the defendant of thereby depriving a person of property or legal rights or otherwise causing injury.” (Civ. Code § 3294(c)(3).) 

 

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 fraud cause of action. Because punitive damages are not allowable under the Song-Beverly Act, punitive damages are not available for any of Plaintiff’s other causes of action. If Plaintiff is able to sufficiently amend his fraud 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 Third and Fifth Causes of Action is sustained with leave to amend.

 

Defendant’s motion to strike is granted.

 

Moving party to give notice.