Judge: Gary I. Micon, Case: 24CHCV04740, Date: 2025-04-23 Tentative Ruling

Case Number: 24CHCV04740    Hearing Date: April 23, 2025    Dept: F43

Dept. F43

Date: 04-23-25

Case # 24CHCV04740, Lauent, LLC, et al. v. Barron, Inc., et al.

Trial Date: None set.

 

DEMURRER AND MOTION TO STRIKE

 

MOVING PARTY: Defendant Jane Barron, Inc.

RESPONDING PARTIES: Plaintiffs Lauent, LLC and Lau Enterprises

 

RELIEF REQUESTED

Order sustaining demurrer to the first cause of action and dismissing the first amended complaint against defendant with prejudice.  Order striking punitive damages against defendant from the first amended complaint.

 

RULING: Demurrer is overruled.  Motion to strike is granted with leave to amend.

 

SUMMARY OF ACTION

 

On December 23, 2024, plaintiffs Lauent, LLC and Lau Enterprises (Plaintiffs) filed a complaint alleging breach of contract and fraud - intentional misrepresentation.  On February 7, 2025, Plaintiffs filed a First Amended Complaint (FAC) against defendants Jane Barron, Inc. (Defendant) and Jeff Abraham, alleging a single cause of action for fraud - intentional misrepresentation and seeking $308,500.00 in compensatory damages and punitive damages.

 

The FAC alleges the following:  Plaintiffs purchased an industrial facility located at 9200 Gazette Avenue in Chatsworth, CA from Defendant.  (FAC, ¶ 8.)  The parties executed a written purchase and sale agreement on December 10, 2021.  (FAC, ¶ 9, Exh. A.)  Defendant Abraham served as the seller’s agent under the agreement.  (FAC, ¶¶ 8-9.)  On December 30, 2021, before close of escrow, the Plaintiffs’ agent emailed defendant Abraham stating that Plaintiffs disapproved of the physical condition of the property, based on an inspection report, which included an assessment of the dilapidated condition of the roof, and requested a price reduction.  (FAC, ¶ 11.)  On December 31, 2021, defendant Abraham replied, rejecting the price reduction and representing that the building was in working order and was properly maintained; that the roof, although older, was constantly maintained by a licensed roofer; and that the minor leaks would be fixed by a licensed roofer the following week on either Tuesday or Thursday.  (FAC, ¶ 12, Exh. B.)

 

Plaintiffs allege that they relied on this representation by waiving escrow contingencies, not obtaining an additional roof inspection report, and proceeding with closing escrow on January 3, 2022.  (FAC, ¶¶ 13, 28.)

 

In January 2023, Plaintiffs asked defendant Abraham for the licensed roofer’s contact information.  (FAC, ¶ 15.)  In December 2023, a dispute arose between Plaintiffs and Defendants when Plaintiffs discovered severe leaking and water damage to the property due to the roof’s dilapidated condition.  (FAC, ¶ 16.)  In February 2024, Plaintiffs again asked for licensed roofer’s contact information as represented in Abraham’s December 31, 2021 email, and for copies of the maintenance records for the roof.  (FAC, ¶ 17.)  On November 1, 2024, Plaintiffs obtained a roof inspection report by A-1 All American Roofing Co. Inc. which recommended a total roof replacement at an estimated cost of $308,500.00.  (FAC, ¶ 18.)  On February 5, 2025, Defendant provided Plaintiffs with roof maintenance records for the first time which showed that Defendant never took any measures to maintain the roof between November 28, 2016 and January 4, 2022.  (FAC, ¶ 19, Exh. C.)

 

Defendant demurs to the FAC’s only cause of action and moves to strike punitive damages against it from the FAC.  Plaintiffs filed oppositions, and Defendant filed replies.

 

MEET AND CONFER

 

Before filing a demurrer or motion to strike, the parties must meet and confer “in person, by telephone, or by video conference.” (Code Civ. Proc., §§ 430.41, subd. (a), 435.5, 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 motion to strike; or (2) that the party who filed the pleading subject to the demurrer or motion to strike 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), 435.5, subd. (a)(3).)  Counsel met and conferred via email on February 11, 2025, but the parties did not come to an agreement.  (Declaration of Michele Seltzer, ¶ 4, Exh. 2.)

 

The court finds that the meet and confer efforts were not sufficient but elects to hear the demurrer and motion to strike.

 

SUMMARY OF ARGUMENTS

 

Defendant asserts that the FAC fails to meet the heightened pleading standard required for fraud claims.  Plaintiffs allege that Defendant’s seller’s agent misrepresented that the roof had been constantly maintained since November 2016 while simultaneously incorporating roof repair records showing that Defendant had paid a construction company for roof repairs on December 11, 2015; March 7, 2016; May 18, 2016; November 22, 2016; January 4, 2022; and January 27, 2022.  Further, the purchase and sale agreement, which Plaintiffs also attached to the FAC, required Plaintiffs to acknowledge that no representations concerning the property were made by the brokers or relied on by Plaintiffs.  Further, defendant Abraham’s use of the term “constantly” is ambiguous at best rather than a falsity.  Finally, Plaintiffs fail to demonstrate justifiable reliance because Plaintiffs admit they had the property inspected before contacting defendant Abraham.  Once Plaintiffs brought the roof issue to defendant Abraham’s attention, defendant Abraham had the roof repaired on Tuesday, January 4, 2022.  Regarding the motion to strike, the FAC’s punitive damages allegations are conclusory and do not show malicious intent, intent to defraud, or despicable behavior.

 

Plaintiffs oppose, asserting that the FAC alleges sufficient facts showing who, when, where, and by what means Defendant’s agent, defendant Abraham, made misrepresentations about the roof being constantly maintained by a licensed roofer.  (FAC, ¶¶ 12-13, 21-25.)  Plaintiffs also plead justifiable reliance on defendant Abraham’s misrepresentations because the terms of the purchase and sale agreement do not disclaim misrepresentations made subsequent to the agreement’s signing.  The court should deny the motion to strike because the FAC alleges that Defendant’s agent, acting within his authority as Defendant’s agent, acted with malice, oppression, and conscious disregard for Plaintiffs’ rights by knowingly making false representations through email to Plaintiffs about the roof’s repair history.  Defendant knew or should have known the representations were false, that Plaintiffs would rely on the representations, and that Plaintiffs would suffer damages.

 

Defendant responds that Plaintiffs fail to allege that any misrepresentation was made about the roof’s condition.  Plaintiffs’ opposition attempts to shift the focus to the roof’s repair history.  However, the December 31, 2021 email made the roof’s condition and age clear.  Defendant cannot be held liable for the disclosure of accessible or visible conditions.  Plaintiffs admit they performed a thorough inspection and that the inspection revealed the condition and deficiencies in the building’s roof.  The roof’s condition was not a fact known only to Defendant or defendant Abraham.  Plaintiffs’ exhibits negate the FAC’s contradictory allegations.  Section 12.2 of the purchase and sale agreement contains an “as-is” provision. Longstanding California law dictates that an “as-is” provisions put buyers on notice that the seller makes no warranties about the quality or condition of the item song.  Plaintiffs still fail to allege malice or intent to defraud.

 

ANALYSIS

 

Demurrer

 

A party may respond to a pleading against it by demurrer based on one or more 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.)

 

First Cause of Action: Fraud – Intentional Misrepresentation

 

Defendant argues that the FAC fails to allege facts sufficient to constitute fraud - intentional misrepresentation and is uncertain.

 

The elements of a fraud - intentional misrepresentation cause of action are (1) misrepresentation, (2) knowledge of falsity, (3) intent to induce reliance on the misrepresentation, (4) justifiable reliance on the misrepresentation, and (5) resulting damages.  (City of Pomona v. Superior Court (2001) 89 Cal.App.4th 793, 803; Lazar v. Superior Court (1996) 12 Cal.4th 631, 638.)  Fraud claims must be pled with specificity; general and conclusory allegations do not suffice.  (Lazar, supra, 12 Cal.4th at p. 645.)  The complaint must plead facts showing  “how, when, where, to whom, and by what means the representations were tendered.”  (Ibid.)  The facts must be clear enough to inform the opposing party what he must answer.  (See Scafidi v. Western Loan & Building Co. (1946) 72 Cal.App.2d 550, 558.) 

 

Plaintiffs allege that they learned about the roof’s dilapidated condition from an inspection report.  (FAC, ¶ 11.)  Plaintiffs subsequently asked Defendant’s agent, broker defendant Abraham, for a price reduction based on the roof’s condition.  (FAC, ¶ 12.)  In response, Defendant’s agent emailed Plaintiffs on December 31, 2021, rejecting the price reduction and stated that “[t]he roof is older,” “has been maintained constantly by a licensed roofer,” and that “[w]ith all of the rain in recent weeks there are some minor leaks, which will be fixed by the same licensed roofer next week either Tuesday or Thursday.”  (FAC, ¶ 12, Exh. B, pp. 1-2.)  Defendant’s roof repair records reflect that the subsequent repairs occurred as evidence through two roof repair payments on Tuesday, January 4, 2022 and Thursday, January 27, 2022.  (FAC, Exh. C, p. 3.)  Defendant’s agent also affirmatively represented that the roof is “older.”

 

However, Plaintiffs correctly point out that Defendant’s agent misrepresented how often the roof was maintained.  Defendant’s repair records identify five (5) instances when the roof was repaired: December 11, 2015, March 7, 2016, November 22-28, 2016, January 4, 2022, and January 27, 2022.  (Exh. C, pp. 1-3.)  It appears that prior to Plaintiffs’ December 30, 2021 email, no roofing repairs had occurred since November 2016.

 

Defendant contends that defendant Abraham’s use of the term “constantly” is puffing rather than a false statement of fact, and that the term is ambiguous rather than intentional.  Statements of opinion are “puffing” and cannot be used to hold a defendant liable for fraud.  (See Hauter v. Zogarts (1975) 14 Cal.3d 104, 111; see also Consumer Advocates v. Echostar Satellite Corp. (2003) 1113 Cal.App.4th 1351, 1361 [holding statements such as “crystal clear” and “CD quality” are “boasts” and “all-but-meaningless superlatives” on which no reasonable consumer would rely when viewing an advertising slogan]. But see Continental Airlines, Inc. v. McDonnell Douglas Corp. (1989) 216 Cal.App.3d 388, 424 [finding representations that include “promises of safety” are representations of fact].)

 

Here, the repair records attached to the FAC contain facts directly contradicting defendant Abraham’s representation.  (FAC, Exh. C.)  Defendant Abraham’s representation that the roof was constantly maintained by a licensed roofer were statements of fact which Plaintiffs could not reasonably dispute at the time before closing escrow because Plaintiffs did not have access to the repair records.  More importantly, the repair records show that the roof was last repaired five (5) years prior to the parties executing the purchase and sale agreement.  Therefore, these records show facts which directly contradict defendant Abraham’s statements about constant maintenance.

 

Next, Defendant contends that the purchase and sale agreement contains an “as-is” provision that put Plaintiffs on notice of the property’s condition and that Defendant gave no warranties.

 

The provision reads:

 

12.2 Buyer hereby acknowledges that, except as otherwise stated in this Agreement, Buyer is purchasing the Property in its existing condition and will, by the time called for herein, make or have waived all inspections of the Property Buyer believes are necessary to protect its own interest in, and its contemplated use of, the Property. The Parties acknowledge that, except as otherwise stated in this Agreement, no representations, inducements, promises, agreements, assurances, oral or written, concerning the Property, or any aspect of the occupational safety and health laws, Hazardous Substance laws, or any other act, ordinance or law, have been made by either Party or Brokers, or relied upon by either Party hereto.

 

(FAC, Exh. A , p. 6.)

 

Plaintiffs argue that this provision is irrelevant because Plaintiffs base their complaint on a misrepresentation that occurred after the purchase and sale agreement was executed. 

 

The court finds that Section 12.2 refers to any representations that occurred or were relied on in executing the purchase and sale agreement.  “When a party learns that he has been defrauded, he may, instead of rescinding, elect to stand on the contract and sue for damages, and, in such case his continued performance of the agreement does not constitute a waiver of his action for damages.”  (Jue v. Smiser (1994) 23 Cal.App.4th 312, 315 [quoting Bagdasarian v. Gragnon (1948) 31 Cal.2d 744, 750].)  Here, Plaintiffs discovered the alleged misrepresentation over a year after closing escrow.  Because Plaintiffs base their claim on misrepresentations made after executing the agreement, this argument fails.

 

Defendant also contends that its disclosure that the roof was old and that the minor leaks were likely due to the recent rain, shifted the burden to Plaintiffs to investigate the roofing issues.

 

Real estate brokers representing sellers have an “affirmative duty to conduct a reasonably competent and diligent inspection of the residential property listed for sale and to disclose to prospective purchasers all facts materially affecting the value or desirability of the property that such an investigation would reveal.”  (See Easton v. Strassburger (1984) 152 Cal.App.3d 90, 102 [emphasis added].)  However, this duty does not apply to the sale of commercial real estate.  (Id. at p. 102 fn. 8; see also  Smith v. Rickard (1988) 205 Cal.App.3d 1354, 1360; Richman v. Hartley (2014) 224 Cal.App.4th 1182, 1192-93.)

 

Real estate brokers for sellers also have a duty to be honest and truthful in their dealings to all parties in a transaction and to refrain from fraudulent misrepresentations.  (See Ward v. Taggart (1959) 51 Cal.2d 736, 741-42; Nguyen v. Scott (1988) 206 Cal.App.3d 725, 735-56; see also Bus. & Prof. Code, §§ 10150, 10176.)  Principal sellers of property have a duty to reveal hidden and material facts concealed by their agent and of which they had knowledge, and failure to disclose them constitutes fraud.  (Herzog v. Capital Co. (1945) 27 Cal.2d 349, 353 [citing Civ. Code, § 1572, subd. (3)].)

 

Defendant Abraham is a real estate broker who represented Defendant in the property sale.  (FAC, ¶ 9(c), (d).)  Defendant Abraham intentionally misrepresented the roof maintenance frequency so that Plaintiffs would waive and approve contingencies and refrain from obtaining an additional roof inspection report.  (FAC, ¶ 27.)  As the principal seller, these misrepresentations are imputed to Defendant.

 

Because Plaintiffs had no reason to believe Defendant lied about the roof maintenance, Plaintiffs relied on the representations and waived and approved the contingencies in the purchase and sale agreement and refrained from repairing the roof or obtaining an additional roof inspection report upon the close of escrow.  (FAC, ¶ 28.)  As a result, Plaintiffs sustained compensatory damages of $308,500.00 in roof repairs.  (FAC, ¶ 29.)

 

Plaintiffs did not discover the misrepresentations until they did a second inspection in 2023 and received a copy of the roof’s maintenance history on February 5, 2025.  (FAC, ¶ 19, Exh. C.)

 

Accordingly, Defendant’s demurrer to the First Cause of Action is overruled.

 

            Legal Standard - Motion to Strike

“Any 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.”  (Code Civ. Proc., § 435.)  A court may strike from the complaint any irrelevant, false, or improper matter.  (Code Civ. Proc., § 436, subd. (a).) The court may also “[s]trike out all or any part of any pleading not drawn or filed in conformity with the laws of this state, a court rule, or an order of the court.”  (Code Civ. Proc., § 436, subd. (b).)  A complaint must plead ultimate facts to support punitive damages.  (Clauson v. Superior Court (1998) 67 Cal.App.4th 1253, 1255; Antelope Valley Groundwater Cases (2020) 59 Cal.App.5th 241, 265 [“[T]he term ‘ultimate fact’ generally refers to a core fact, such as an essential element of a claim.”].)

 

            Punitive Damages

Defendant moves to strike Plaintiff’s request for punitive damages concerning Defendant (FAC, ¶ 30; Prayer, paragraph 1.b) from the FAC.

 

To state a prima facie claim for punitive damages, a complaint must set forth specific facts demonstrating the elements stated in Civil Code section 3294.  (College Hosp., Inc. v. Superior Court (1994) 8 Cal.4th 704, 721; see also Brousseau v. Jarrett (1977) 73 Cal.App.3d 864, 872.)  Malice is “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 p. 725; Civ. Code, § 3294, subd. (c)(1).)  Oppression is “despicable conduct that subjects a person to cruel and unjust hardship in conscious disregard of that person’s rights.”  (Civ. Code, § 3294, subd. (c)(2).)  Fraud is “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, subd. (c)(3).)  “Malice and oppression may be inferred from the circumstances of a defendant’s conduct.”  (J. R. Norton Co. v. General Teamsters, Warehousemen & Helpers Union, Local 890 (1989) 208 Cal.App.3d 430, 444.)

 

Punitive damages are not available for claims arising from breach of contractual obligations.  (Civ. Code, § 3294, subd. (a); Cates Constructions, Inc. v. Talbot Partners (1999) 21 Cal.4th 28, 61; Ginsberg v. Gamson (2012) 205 Cal.App.4th 873, 901.)  Absent an independent tort, contractual punitive damages are not awarded even if the defendant’s conduct was willful, fraudulent, or malicious.  (Myers Building Indus. Ltd. v. Interface Technology, Inc. (1993) 13 Cal.App.4th 949, 959; see also Applied Equipment Corp. v. Litton Saudi Arabia Ltd. (1994) 7 Cal.4th 503, 516; College Hosp., Inc., supra, 8 Cal.4th 704, 725.)

 

“A corporation may be held liable for punitive damages for the acts of its agents and employees when the act is motivated by actual malice or done under circumstances amounting to oppression, providing that the act is done with the knowledge or under the direction of corporate officials having power to bind the corporation.”  (J. R. Norton Co., supra, 208 Cal.App.3d at p. 445.)  A corporation may also be held liable for punitive damages for the acts of specific agents or employees if the specific agent was an officer, director other managing agent, acting on behalf of the corporation.  (CACI No. 3943.) 

 

Although Plaintiffs sufficiently allege a fraud cause of action against Defendant and that defendant Abraham maliciously made misrepresentations with a disregard for Plaintiffs’ rights, Plaintiffs do not sufficiently plead facts showing that any corporate officer with the discretion to set corporate policy ratified or authorized defendant Abraham’s misrepresentations.  The FAC merely states that each defendant’s conduct was authorized and ratified by the other defendants.

 

Therefore, the court strikes the first amended complaint’s punitive damages allegations (FAC, ¶ 30; Prayer, paragraph 1.b) as to Defendant Jane Barron, Inc., with leave to amend.

 

CONCLUSION

Defendant Jane Barron, Inc.’s demurrer to the First Amended Complaint’s First Cause of Action is overruled.

 

Defendant Jane Barron, Inc.’s motion to strike punitive damages against defendant Jane Barron from the First Amended Complaint is granted with leave to amend.  The court strikes the following from the First Amended Complaint: Paragraph 30; Prayer for Relief, paragraph 1.b.

 

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

 

Defendant Jane Barron, Inc. to give notice.

 





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