Judge: Gregory Keosian, Case: 22STCV14401, Date: 2022-09-01 Tentative Ruling

Case Number: 22STCV14401    Hearing Date: September 1, 2022    Dept: 61

Defendants Askar Ranjbar, Mohammad Ranjbar, and Mahamed Jafar’s Demurrer to the Complaint is SUSTAINED with leave to amend as to the first, third, and fourth causes of action alleged against Defendants Mohammad Ranjbar and Mohamed Jafar, and OVERRULED as to all claims alleged against Askar Ranjbar.

 

Defendants’ Motion to Strike Portions of the Complaint is GRANTED without leave to amend as to the prayer for attorney fees, and is otherwise DENIED.

I.                DEMURRER

A demurrer should be sustained only where the defects appear on the face of the pleading or are judicially noticed. (Code Civ. Pro., §§ 430.30, et seq.) In particular, as is relevant here, a court should sustain a demurrer if a complaint does not allege facts that are legally sufficient to constitute a cause of action. (See id. § 430.10, subd. (e).) As the Supreme Court held in Blank v. Kirwan (1985) Cal.3d 311: “We treat the demurrer as admitting all material facts properly pleaded, but not contentions, deductions or conclusions of fact or law. . . . Further, we give the complaint a reasonable interpretation, reading it as a whole and its parts in their context.” (Id. at p. 318; see also Hahn. v. Mirda (2007) 147 Cal.App.4th 740, 747 [“A demurrer tests the pleadings alone and not the evidence or other extrinsic matters. Therefore, it lies only where the defects appear on the face of the pleading or are judicially noticed. [Citation.]”)

 

“In determining whether the complaint is sufficient as against the demurrer … if on consideration of all the facts stated it appears the plaintiff is entitled to any relief at the hands of the court against the defendants the complaint will be held good although the facts may not be clearly stated.”  (Gressley v. Williams (1961) 193 Cal.App.2d 636, 639.)

 

A demurrer for uncertainty is strictly construed, even where a complaint is in some respects uncertain, because ambiguities can be clarified under modern discovery procedures.” (Khoury v. Maly’s of Cal., Inc. (1993) 14 Cal.App.4th 612, 616.) Such demurrers “are disfavored, and are granted only if the pleading is so incomprehensible that a defendant cannot reasonably respond.” (Mahan v. Charles W. Chan Insurance Agency, Inc. (2017) 14 Cal.App.5th 841, 848.)

 

A demurrer should not be sustained without leave to amend if the complaint, liberally construed, can state a cause of action under any theory or if there is a reasonable possibility the defect can be cured by amendment. (Schifando v. City of Los Angeles, supra, 31 Cal.4th at p. 1081.) The demurrer also may be sustained without leave to amend where the nature of the defects and previous unsuccessful attempts to plead render it probable plaintiff cannot state a cause of action. (Krawitz v. Rusch (1989) 209 Cal.App.3d 957, 967.)

 

Defendants Mohamed Jafar and Askar and Mohammad Ranjbar (Defendants) demurrer to Plaintiff Hamada Abdulla’s (Plaintiff) complaint on the grounds that the breach of contract claim (and the derivative claim for declaratory relief) alleges no facts supporting liability against defendants other than Askar Ranjbar. (Demurrer at pp. 4–5.) Defendants further argue that Plaintiff does not adequately plead conversion because he does not plead rightful possession of the property, nor the specific property involved, nor which defendant committed what specific acts. (Demurrer at pp. 6–7.) Defendants finally argue that the third cause of action for fraud is not alleged with the requisite specificity. (Demurrer at pp. 8–9.)

 

There is merit to Defendants’ first argument, because the breach of contract allegations, and the attached exhibits, allege only written contracts with Askar Ranjbar, not with co-defendants Mohammad Ranjbar and Mohamed Jafar. The existence of a contract is an element of a breach of contract claim. (See D'Arrigo Bros. of California v. United Farmworkers of America (2014) 224 Cal.App.4th 790, 800.) But while the first cause of action is alleged against “Defendants” as a group, the only contracts attached to the Complaint are those between Plaintiff and Askar Ranjbar. (Complaint Exhs. 1–3.) There is no alleged basis to plead a breach of contract claim against the other defendants. The demurrer is therefore SUSTAINED with leave to amend as to the first and fourth causes of action for breach of contract and declaratory relief as to Defendants Mohammad Ranjbar and Mohamed Jafar.

 

Defendants’ arguments as to the conversion claim are less persuasive. Contrary to Defendants’ argument, Plaintiff alleges possession of the items in question by virtue of allegations that the personal property was “of Hamada,” i.e. belonging to Plaintiff. (Complaint ¶ 14.) This allegation is sufficient to satisfy the element of conversion requiring “the plaintiff's ownership or right to possession of personal property.” (Regent Alliance Ltd. v. Rabizadeh (2014) 231 Cal.App.4th 1177, 1181.) The demurrer is therefore OVERRULED as to the second cause of action for conversion.

 

Defendants’ final argument with respect to the insufficiency of the fraud claim once more applies most persuasively to Defendants Mohammad Ranjbar and Mohamed Jafar. The elements of fraud are: (1) misrepresentation (false representation, concealment, or nondisclosure); (2) knowledge of falsity (scienter); (3) intent to defraud or induce reliance; (4) justifiable reliance; and (5) damages.  (See Lazar v. Superior Court (1996) 12 Cal.4th 631, 638.) It is well-established that “[t]o withstand a demurrer, the facts constituting every element of fraud must be alleged with particularity, and the claim cannot be salvaged by references to the general policy favoring the liberal construction of pleadings.” (Goldrich v. Natural Y Surgical Specialties, Inc. (1994) 25 Cal.App.4th 772, 782.) “This particularity requirement necessitates pleading facts which show how, when, where, to whom, and by what means the representations were tendered.” (Lazar, supra, 12 Cal.4th at p. 645 (internal quotation marks omitted).) Here, the allegations of misrepresentation are reasonably specific, and refer to the final promise in the final contract to turn over Askar’s business to Plaintiff. (Complaint ¶ 40, Exh. 3.) But again, there are no allegations implicating the other defendants in this contract.

 

The demurrer is thus SUSTAINED with leave to amend as to the first, third, and fourth causes of action alleged against Defendants Mohammad Ranjbar and Mohamed Jafar, and OVERRULED as to all claims alleged against Askar Ranjbar.

 

II.             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(b)(1)). The notice of motion to strike a portion of a pleading shall quote in full the portions sought to be stricken except where the motion is to strike an entire paragraph, cause of action, count or defense. (California Rules of Court Rule 3.1322.)

The grounds for a motion to strike shall appear on the face of the challenged pleading or form any matter of which the court is required to take judicial notice. (Code Civ. Proc., § 437(a)). The court then may strike out any irrelevant, false, or improper matter inserted in any pleading and strike 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.) When the defect which justifies striking a complaint is capable of cure, the court should allow leave to amend. (Perlman v. Municipal Court (1979) 99 Cal.App.3d 568, 575.)

Defendants in their motion to strike repeat the arguments raised in demurrer, and further move to strike the prayer for punitive damages and the prayer for attorney fees. (Motion at pp. 4–6.)

Punitive damages are allowed in non-contract cases when a defendant is guilty of “oppression, fraud, or malice . . . .” (Civ. Code § 3294.) The terms are defined as:

“Malice” means conduct which is 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.

“Oppression” means despicable conduct that subjects a person to cruel and unjust hardship in conscious disregard of that person's rights.

“Fraud” means 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.

Something more than the mere commission of a tort is always required for punitive damages. (Taylor v. Superior Court (1979) 24 Cal.3d 890, 894.) Proof of negligence, gross negligence, or recklessness is insufficient to warrant an award of punitive damages. (Dawes v. Sup.Ct. (Mardian) (1980) 111 Cal.App.3d 82, 88–89.) Punitive damages may be recovered in an action for negligence or other nonintentional torts if the plaintiff pleads and proves that the defendant acted with the state of mind described as “conscious disregard” of the potential dangers to others. (Pfeifer v. John Crane, Inc. (2013) 220 Cal.App.4th 1270, 1299.) When malice is based on a defendant’s conscious disregard of Plaintiff’s rights, the conduct must be both despicable and willful. (College Hospital v. Superior Court (1994) 8 Cal.4th 794, 713 (“College Hospital”).)

Here, Plaintiff has alleged fraud on the part of Askar Ranjbar, as would support a prayer for punitive damages against him. He has also alleged conversion on the part of all three defendants, in which they stole thousands of dollars worth of personal property from his business, “in an intentional and calculated effort to misappropriate plaintiff’s personal property . . . with the intent to permanently deprive plaintiff from the benefits thereof.” (Complaint ¶ 36.) These allegations support the existence of malice and oppression against all defendants, and therefore punitive damages.

However, Defendants are correct as to the availability of attorney fees in this case. Parties must ordinarily bear their own attorney fees unless statute or contract provide otherwise. (See Code Civ. Proc. § 1021.) Here, no statute allowing fees is pleaded or argued, and no provision for same is included in the contracts that Plaintiff attaches to the Complaint. Plaintiff makes no argument for the availability of fees in opposition to this motion.

The motion is therefore GRANTED without leave to amend as to the prayer for attorney fees, and is otherwise DENIED.