Judge: Gregory Keosian, Case: 22STCV35368, Date: 2023-03-20 Tentative Ruling

Case Number: 22STCV35368    Hearing Date: March 20, 2023    Dept: 61

Defendant Renaissance Imaging Medical Associates, Inc.’s Demurrer and Motion to Strike Portions of Plaintiff Annalee Santos’s Complaint is SUSTAINED with leave to amend as to the ninth cause of action, and is otherwise OVERRULED and 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.)

 

Defendant Renaissance Medical Imaging Associates, Inc. (Defendant) demurrers to each cause of action alleged in Plaintiff Annalee Santos’s complaint on the grounds that Plaintiff fails to plead a constructive termination, and fails to plead a causal link between her termination of employment and her disability. (Demurrer at pp. 4–6.) Defendant also argues that Plaintiff does not plead that she was denied any accommodation, or that the interactive process to find one failed, given that she was granted medical leave. (Demurrer at pp. 6–7.) Defendant further argues that Plaintiff does not allege that she was eligible for statutory medical leave under FMLA or CFRA, and that she does not allege a claim for failure to provide employment records under Labor Code § 226. (Demurrer at pp. 7–8.)

 

To establish a discrimination claim under FEHA, an employee must prove the following elements: “(1) he was a member of a protected class, (2) he was qualified for the position he sought or was performing competently in the position he held, (3) he suffered an adverse employment action, such as termination, demotion, or denial of an available job, and (4) some other circumstance suggests discriminatory motive.” (Dinslage v. City and County of San Francisco (2016) 5 Cal.App.5th 368, 378.)

 

Defendant’s arguments against Plaintiff’s FEHA claims rest upon a flagrant misinterpretation of the pleadings. Specifically, while Defendant argues that Plaintiff fails to allege circumstances amounting to a constructive termination, the Complaint does not attempt to allege such a theory: it alleges that Plaintiff’s employment was “summarily terminated” after she “refused to resign.” (Complaint ¶ 20.) Plaintiff alleges she was terminated by adverse act of Defendant, not by her own volition.

 

The Complaint also alleges a causal connection between Plaintiff’s termination and Defendant’s discriminatory motive, specifically by noting that Plaintiff was terminated one month after beginning medical leave. (See Arteaga v. Brink’s, Inc. (2008) 163 Cal.App.4th 327, 353 [temporal proximity between disclosure of disability and adverse action supported prima facie case of discrimination].)

 

Defendant’s arguments as to the reasonable accommodation and interactive process claims also fail. Defendant claims that neither claim can proceed because Plaintiff alleges she was given leave. (Demurrer at pp. 6–7.) Defendant is correct that an element of a reasonable accommodation claim is that “the employer failed to reasonably accommodate the employee's disability. (Nealy v. City of Santa Monica (2015) 234 Cal.App.4th 359, 373, citations omitted.) But the Complaint alleges just such a failure to accommodate here — namely, that Defendant offered Plaintiff leave only to terminate her employment prior to the leave’s conclusion. (Complaint ¶ 20.) The Complaint thus alleges that Defendant deprived Plaintiff of reasonable accommodation by cutting her leave prematurely short.

 For the same reasons as stated above, Defendant’s derivative arguments as to the fifth cause of action for failure to prevent FEHA violations fails. (Demurrer at p. 7.) The demurrer is therefore OVERRULED as to the first through fifth causes of action.

Defendant next argues that Plaintiff was ineligible for leave under either CFRA or FMLA, as her leave began before she had worked one year for Defendant. (Demurrer at pp. 7–8.) Defendant correctly states the law, as these statutes require a 12-month period of work with the employer, and 1,250 hours of service for eligibility. (Gov. Code § 12945.2, subd. (a); 29 U.S.C. § 2611, subd. (2)(A).) However, Defendant calculates Plaintiff’s period of employment from the date of her hiring — February 27, 2020 — to the date of her taking leave on February 17, 2021, rather than the date she alleges her employment was terminated on March 26, 2021. (Complaint ¶ 20.) When Plaintiff was terminated, she had been employed with Defendant for the 12-month period. Thus the demurrer to the seventh cause of action is OVERRULED.

Defendant next argues that Plaintiff’s eighth and ninth causes of action for failure to turn over employment and personnel records fail because she alleges a failure to turn over “general employment or personnel records,” not the particular types of records that are legally required to be turned over pursuant to Labor Code § 226. (Demurrer at p. 8.) Defendant does not cite authority for the proposition that characterizing the records due under this section must be particularly delimited according to the precise payroll records described in Labor Code § 226, subd. (a). Plaintiff alleges that she has sought records required to be turned over pursuant to subdivision (b) of that statute, but that Defendant has failed to do so. (Complaint ¶¶ 121, 125.) To the extent these claims have a defect, it is that the ninth is duplicative of the eighth in apparently seeking identical categories of documents under the same section. (Ibid.) Plaintiff in opposition states an intention to amend the ninth cause of action. (Opposition at p. 5, fn. 1.) The demurrer is therefore OVERRULED as to the eighth cause of action, and SUSTAINED with leave to amend as to the ninth cause of action.

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.)

Defendant moves to strike the prayer for punitive damages. (Motion at pp. 8–11.)

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, the Complaint alleges something more than the mere commission of a tort, which is sufficient to invoke punitive damages. Plaintiff does not merely allege that she was terminated while on disability leave, but that she was terminated while on-site at Defendant’s location, which she was visiting to obtain medical services related to her disability. (Complaint ¶ 20.) Plaintiff alleges that Defendant was aware of the reason for her visit, and took advantage of the opportunity to pressure her to “voluntarily resign” her position while she was still under “the residual influence of anesthetics.” (Complaint ¶ 20.) Plaintiff was terminated after she refused to resign and “complained of the abusive treatment.” (Complaint ¶ 20.) Plaintiff thus alleges that Defendant engaged in despicable conduct that subjected her to cruel and unjust hardship in conscious disregard of her rights.

Defendant further argues that Plaintiff does not allege employer ratification as required under Civil Code § 3294, subd. (b). (Demurrer at pp. 10–11.) But the Complaint alleges that the conduct at issue was directed or ratified by a managing agent of Defendant’s, just as the section requires. (Complaint ¶ 34.) Defendant presents no authority for the proposition that the specific identity of the managing agent need be pleaded.

The motion to strike is therefore DENIED.