Judge: Gregory Keosian, Case: 23STCV16395, Date: 2023-10-25 Tentative Ruling

Case Number: 23STCV16395    Hearing Date: October 25, 2023    Dept: 61

Defendant Kimball, Tirey & St. John, LLP’s Anti-SLAPP Motion is GRANTED

 

Defendant PIH Health Good Samaritan Hospital’s Demurrer to the Complaint is SUSTAINED without leave to amend. The motion to strike is DENIED as moot.

 

Defendants to provide notice.

 

I.                   SPECIAL MOTION TO STRIKE

In 1992 the Legislature enacted Code of Civil Procedure section 425.16 as a remedy for the “disturbing increase in lawsuits brought primarily to chill the valid exercise of the constitutional rights of freedom of speech and petition for the redress of grievances.” (Code Civ. Proc., §425.16, subd. (a); Wilcox v. Superior Court (1994) 27 Cal.App.4th 809, 817.)  The lawsuits are commonly referred to as “SLAPP” lawsuits, an acronym for “strategic lawsuit against public participation.” (Equilon Enterprises, LLC v. Consumer Cause, Inc. (2002) 29 Cal.4th 53, 57, fn. 1.) A defendant opposing a SLAPP claim may bring an “anti-SLAPP” special motion to strike any cause of action “arising from any act of that person in furtherance of the person's right of petition or free speech under the United States Constitution or the California Constitution in connection with a public issue . . . .” (Code Civ. Proc., § 425.16, subd. (b)(1).) An anti-SLAPP motion may be addressed to individual causes of action and need not be directed to the complaint as a whole. (Shekhter v. Financial Indemnity Co. (2001) 89 Cal.app.4th 141, 150.)

 

In ruling on an anti-SLAPP motion, a trial court uses a “summary-judgment-like procedure at any early stage of the litigation.” (Varian Medical Systems, Inc. v. Delfino (2005) 35 Cal.4th 180, 192.) This is a two-step process.  First, the defendants must show that the acts of which the plaintiff complains were taken “in furtherance of the [defendant]’s right of petition or free speech under the United States of California Constitution in connection with a public issue.” (Code Civ. Proc., §425.16 subd. (b)(1).) Next, if the defendant carries that burden, the burden shift to the plaintiff to demonstrate a probability of prevailing on the claim. (Code Civ. Proc., § 425.16 subd. (b)(3).)

 

In making both determinations the trial court considers “the pleadings, and supporting and opposing affidavits stating the facts upon which the liability or defense is based.” (Code Civ. Proc., § 425.16, subd. (b)(2); Equilon Enterprises, supra, 29 Cal.4th at p. 67.)

 

Defendant Kimball, Tirey & St. John LLP (KTS) moves to strike the Complaint filed by Plaintiff Moné Shaw (Plaintiff) on the grounds that, to the extent any of the claims against KTS are specifically identifiable, they derive from KTS’s alleged service of a forged notice of hearing for an OSC re: failure to file proof of service, and as such constitute claims arising from protected litigation related activity and communications privileged under Civil Code § 47. (Motion at pp. 3–6, 7–10.)

 

A.    PROTECTED ACTIVITY

 

The anti-SLAPP statute defines protected activities as:

 

(1) any written or oral statement or writing made before a legislative, executive, or judicial proceeding, or any other official proceeding authorized by law, (2) any written or oral statement or writing made in connection with an issue under consideration or review by a legislative, executive, or judicial body, or any other official proceeding authorized by law, (3) any written or oral statement or writing made in a place open to the public or a public forum in connection with an issue of public interest, or (4) any other conduct in furtherance of the exercise of the constitutional right of petition or the constitutional right of free speech in connection with a public issue or an issue of public interest.

 

(Code Civ. Proc., § 425.16, subd. (e), emphasis added.)

 

Courts have “have adopted a fairly expansive view of what constitutes litigation-related activities within the scope of section 425.16.” (Kashian v. Harriman (2002) 98 Cal.App.4th 892, 908.) “Correspondence made in anticipation of litigation “contemplated in good faith and under serious consideration can be a petitioning activity protected by the anti-SLAPP statute.” (Lunada Biomedical v. Nunez (2014) 230 Cal.App.4th 459, 472.) The court is mindful that the defendant bears the burden of making this initial showing. (See Navellier v. Sletten (2002) 29 Cal.4th 82, 88.)

It is the “principal thrust or gravamen of a plaintiff’s cause of action” that determines whether the anti-SLAPP statute applies. (Contreras v. Dowling (2016) 5 Cal.App.5th 394, 405.) This gravamen is “defined by the acts on which liability is based, not some philosophical thrust or legal essence of the cause of action.” (Ibid.)

Here, the Complaint against KTS appears to derive from its service of an alleged forged notice of OSC re: failure to file proof of service in an underlying unlawful detainer case. KTS presents the declaration of Christopher Evans, a KTS partner, who states that KTS was retained by CIRCA 1200, LLC to represent it in an unlawful detainer proceeding, and that the notice of hearing was merely a filled-out LACIV 240 form served with the summons and complaint. (Evans Decl. ¶¶ 3–5.)

Defendant is correct that the present lawsuit against it arises out of protected activity. Litigation activity, including the service of notices prerequisite to the bringing of an unlawful detainer suit, is protected activity under Code of Civil Procedure § 425.16. (See Wallace v. McCubbin (2011) 196 Cal.App.4th 1169, 1183.) The service of the notice of hearing at issue here is therefore protected, and Plaintiff may be required to justify her claims.

B.     LIKELIHOOD OF PREVAILING

After a defendant meets their burden of showing that the gravamen of the complaint involves protected activity, the plaintiff must then “demonstrate that the complaint is both legally sufficient and supported by a sufficient prima facie showing of facts to sustain a favorable judgment if the evidence submitted by the plaintiff is credited.” (Matson v. Dvorak (1995) 40 Cal.App.4th 539, 548.) A defendant can meet its burden if it can establish that the plaintiff cannot overcome an affirmative defense. (Birkner v. Lam (2007) 156 Cal.App.4th 275 at 285.)

 

[A] plaintiff cannot simply rely on his or her pleadings, even if verified. Rather, the plaintiff must adduce competent, admissible evidence.” (Grenier v. Taylor (2015) 234 Cal.App.4th 471, 480.)

“Legally sufficient” means that the cause of action would satisfy a demurrer. (Dowling v. Zimmerman (2001) 85 Cal.App.4th 1400, 1421.) The evidentiary showing must be made by competent and admissible evidence. (Morrow v. Los Angeles Unified School District (2007) 149 Cal.App.4th 1424, 1444.) Proof, however, cannot be made by declaration based on information and belief. (Evans v. Unkow (1995) 38 Cal.App.4th 1490, 1497–1498.) The question is whether the plaintiff has presented evidence in opposition to the defendant’s motion that, if believed by the trier of fact, is sufficient to support a judgment in the plaintiff’s favor. (Zamos v. Stroud (2004) 32 Cal.4th 958, 965.)

 

Plaintiff here has filed no opposition to the motion, and made no showing as to the legal or evidentiary sufficiency of her claims against KTS.

The anti-SLAPP motion is therefore GRANTED.

II.                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) 39 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 PIH Health Good Samaritan Hospital (PIH) demurrers to the Complaint on the grounds that it fails to comply with CRC Rule 2.112, requiring the serial numbering of each cause of action and the parties by and against which it is asserted. (Demurrer at p. 4.) PIH also argues that the demurrer is uncertain, and fails to allege the substantive elements of a claim for medical negligence. (Demurrer at pp. 4–5.)

 

PIH’s arguments are persuasive. CRC Rule 2.112 requires a complaint to state, for each cause of action or count in a complaint, “[i]ts number (e.g. ‘first cause of action’),” its “nature (e.g. ‘for fraud’),” and “[t]he party or parties to whom it is directed (e.g. ‘against defendant Smith’).” (CRC Rule 2.112.) No such information is included in the Complaint here, as a number of legal theories are set forth with no serial numbering, indication as to whom they are directed, or the substantive basis therefore. Indeed, PIH is correct that the complaint as a whole is uncertain, as it is “so incomprehensible that a defendant cannot reasonably respond.” (Mahan, supra, 14 Cal.App.5th at p. 848.)

 

It is reasonable to infer from the Complaint that a medical malpractice claim is raised against PIH. However, this claim is ill-pleaded. “The elements of a cause of action for medical malpractice are: (1) a duty to use such skill, prudence, and diligence as other members of the profession commonly possess and exercise; (2) a breach of the duty; (3) a proximate causal connection between the negligent conduct and the injury; and (4) resulting loss or damage.” (Lattimore v. Dickey (2015) 239 Cal.App.4th 959, 968.) Plaintiff alleges that while at PIH, she was “denied basic human rights, misdiagnosed, . . . and mistreated, while each medical Doe staff ignored her pleads for medical attention, as her breathing condition continued to deteriorate.” (Complaint at p. 11.) This allegation, without elaboration, does not allege duty, causation, or damages.

The demurrer is therefore SUSTAINED as to all claims alleged against PIH, without leave to amend. PIH’s concurrently filed motion to strike the prayer for punitive damages, as well as Plaintiff’s allegation that PIH is a public entity, is DENIED as moot.