Judge: Helen Zukin, Case: SC126981, Date: 2022-09-16 Tentative Ruling

Case Number: SC126981    Hearing Date: September 16, 2022    Dept: 207

Background

 

Plaintiff, Hooman M. Melamed, M.D. (“Plaintiff”) owns a condominium located within a development known as The Ridge Condominium. This is a consolidated action arising from a series of interrelated disputes between Plaintiff and the homeowners’ association for the development, Defendant and Cross-Complainant The Ridge Condominium Association (“Defendant”), as well as related parties, concerning, among other issues, Defendant’s refusal to allow Plaintiff a variance in the parking rules for the property to accommodate a disability following Plaintiff’s orthopedic surgery.

 

On July 7, 2017, Defendant filed a Cross-Complaint against Plaintiff alleging causes of action for breach of the development’s governing documents and declaratory relief. Defendant now moves for summary adjudication of several causes of action and affirmative defenses asserted by the parties in these consolidated actions as follows: (1) Defendant’s cause of action for breach of governing documents, (2) Defendant’s claim for monetary damages in connection with its claim for breach of governing documents, (3) Plaintiff’s affirmative defense of selective enforcement to Defendant’s cause of action for breach of the governing documents, (4) Plaintiff’s first cause of action for violation of the Fair Housing Act in consolidated case 18SMCV00086, (5) Plaintiff’s second cause of action for violation of the California Fair Employment and Housing Act (“FEHA”) in consolidated case 18SMCV00086, (6) Plaintiff’s third cause of action for violations of the Unruh Civil Rights Act in consolidated case 18SMCV00086, and (7) Plaintiff’s fourth cause of action for breach of fiduciary duty in consolidated case 18SMCV00086.

 

Request for Judicial Notice

 

Plaintiff requests the Court take judicial notice of pleadings filed in consolidated actions 18SMCV00086 and SC126981 and an order entered in action SC126981. Plaintiff’s request is unopposed and is GRANTED.

 

Objections to Evidence

 

Defendant’s objections to the Declaration of John Cruikshank are GRANTED as to objections 12, 15, and 16, and are otherwise DENIED.

 

Defendant’s objections to the Declaration of Plaintiff are GRANTED as to objections 5, 7, 8, and 14, and are otherwise DENIED.

 

Defendant’s objections to the Declaration of Andrew Zimbaldi are GRANTED as to objections 4, 9, 11, 12, 15, 16, and 18, and are otherwise DENIED.

 

Defendant’s objection to the Declaration of Gidon Vardi is GRANTED as to paragraphs 19-28 and is otherwise DENIED.

 

Defendant’s objection to the Declaration of Iraj Khoubnazar is GRANTED as to paragraph 7 and is otherwise DENIED.

 

Plaintiff’s objections to the Declaration of Jeff Ramirez are DENIED.

 

Plaintiff’s objections to the Declaration of Yegeniv Postnyy are DENIED.

 

Plaintiff’s objection to the Declaration of Carol Tolchin is DENIED.

 

Summary Adjudication Standard

 

A party may move for summary adjudication as to one or more causes of action, affirmative defenses, claims for damages, or issues of duty if the party contends there is no merit to the cause of action, defense, or claim for damages, or if the party contends there is no duty owed. (See CCP §437c(f)(1).) “A motion for summary adjudication shall be granted only if it completely disposes of a cause of action, an affirmative defense, a claim for damages, or an issue of duty.” (Ibid.) A party moving for summary adjudication bears the burden of persuasion that there are no triable issues of material facts. Aguilar v. Atlantic Richfield Co. (2001) 25 Cal.4th 826, 850.

 

In analyzing motions for summary adjudication, the court must “view the evidence in the light most favorable to the opposing party and accept all inferences reasonably drawn therefrom.” (Hinesley v. Oakshade Town Center (2005) 135 Cal.App.4th 289, 294; Dore v. Arnold Worldwide, Inc. (2006) 39 Cal.4th 384, 389 (Courts “liberally construe the evidence in support of the party opposing summary judgment and resolve doubts concerning the evidence in favor of that party”).) A motion for summary adjudication must be denied where the moving party's evidence does not prove all material facts, even in the absence of any opposition (Leyva v. Sup. Ct. (1985) 164 Cal.App.3d 462, 475) or where the opposition is weak (Salasguevara v. Wyeth Labs., Inc. (1990) 222 Cal.App.3d 379, 384, 387).

 

As to each claim as framed by the complaint, a cross-complainant moving for summary adjudication must satisfy the initial burden of proof by establishing “each element of the cause of action entitling the party to judgment on the cause of action.” (C.C.P. § 437c(p)(1).) Once the plaintiff has met this burden, the burden shifts to the defendant to show a triable issue of one or more material facts exists as to the cause of action or a defense thereto. (C.C.P. § 437c(p)(1).) A defendant moving for summary adjudication as to a plaintiff’s claim or cause of action must show “one or more elements of the cause of action, even if not separately pleaded, cannot be established, or that there is a complete defense to the cause of action. Once the defendant or cross-defendant has met that burden, the burden shifts to the plaintiff or cross-complainant to show that a triable issue of one or more material facts exists as to the cause of action or a defense thereto.” (C.C.P. § 437c(p)(2).)

 

Analysis

 

As an initial matter, the Court notes the second issue presented by Defendant’s motion seeks summary adjudication of Defendant’s claim for monetary damages in connection with its cause of action against Plaintiff for breach of the development’s governing documents. Pursuant to Code Civ. Proc. § 437c(f)(1), summary adjudication of a claim for damages is limited to summary adjudication of claims for punitive damages. (CCP § 437c(f)(1) [“a party may move for summary adjudication as to … one or more claims for damages … if that party contends … that there is no merit to a claim for damages as specified in Section 3294 of the Civil Code…”].) Civil Code § 3294 pertains to punitive damages. As the statute does not permit summary adjudication of Defendant’s claim for monetary damages, Defendant’s motion for summary adjudication of this claim is DENIED.

 

The remaining issues presented by Defendant’s motion can be divided into two groups: (1) Defendant’s claim to recover unpaid parking fines levied against Plaintiff in September 2016 (Issues 1 and 3), and (2) Plaintiff’s claims against Defendant for failure to respond to his purported September 10, 2018, request for accommodation related to the parking rules stemming from a surgery (Issues 4-7).

 

            1.         Parking Fines

 

Defendant moves for summary adjudication as to its cause of action for breach of the development’s governing documents stemming from Plaintiff’s unpaid parking violations, as well as to Plaintiff’s affirmative defense of selective enforcement. Defendant’s cause of action for breach of the governing documents is asserted in a Cross-Complaint filed in case SC126981. Defendant alleges Plaintiff has been cited 70 times for violating parking rules, which resulted in the Board of Directors issuing Plaintiff a fine in the amount of $3,075, which he has failed to pay. Plaintiff has alleged, among other thing, that Defendant has targeted him personally by selectively enforcing the parking rules against him while allowing other violators to go unpunished.

 

The Court notes Defendant previously moved for summary adjudication of this cause of action and Plaintiff’s affirmative defense of selective enforcement, which was denied by the Court on August 16, 2018. Under Code Civ. Proc. § 437c(f)(2), “A party shall not move for summary judgment based on issues asserted in a prior motion for summary adjudication and denied by the court unless that party establishes, to the satisfaction of the court, newly discovered facts or circumstances or a change of law supporting the issues reasserted in the summary judgment motion.” Thus, before the Court turns to the merits of Defendant’s motion, it must first determine whether Defendant has shown newly discovered facts, circumstances, or a change of law which can justify Defendant’s filing of a second motion for summary adjudication on these issues.

 

The Court notes Defendant’s February 22, 2018, motion for summary judgment, or, in the alternative, summary adjudication sought summary adjudication of Defendant’s cause of action for breach of the governing documents, Defendant’s claim for monetary damages in connection with that cause of action, as well as Plaintiff’s affirmative defense of selective enforcement. In other words, the prior motion sought summary adjudication of Issues 1, 2, and 3 in Defendant’s instant motion.

 

In denying Defendant’s prior motion for summary adjudication, the Court found Defendant had not sufficiently established Plaintiff had in fact violated the governing documents as Defendant had merely submitted the citations themselves as evidence of the violation, along with deposition testimony from Plaintiff admitting to one potential violation. The Court held this evidence was insufficient to meet Defendant’s initial burden in establishing Plaintiff had “actually parked in a way that violated the Governing Documents.” (Order at 6.)

 

Defendant acknowledges this prior ruling but makes no mention of Code Civ. Proc. § 437c(f)(2). Defendant argues its instant motion “addresses Judge Karlan’s concern” as expressed in denying the prior motion by attaching “the Declarations of Yegeniv Postnyy and Jeff Ramirez, the two patrol officers who issued the majority of the parking citations at issue in the Association’s cross-complaint….” (Motion at 15.) In their declarations, Mr. Postnyy states he personally observed 38 parking violations at Defendant’s residence for blocking the walkway/sidewalk (Postnyy Decl. at ¶5) and Mr. Ramirez states he personally observed an additional 12 such violations (Ramirez Decl. ¶6).

 

Defendant has not made any showing as to whether this information was known to it at the time it filed its previous motion for summary adjudication or “newly discovered” sometime after the Court’s August 2018 ruling. The Court notes the citations themselves, which were attached to Defendant’s prior motion, indicate the name of the patrol officer who issued the citation. It thus appears Defendant was aware of the identity of the individuals who had personally witnessed Plaintiff’s alleged violations at the time it filed its previous motion.

 

Moreover, ordinarily, the right to bring a renewed motion carries with it a responsibility of diligence with respect to obtaining the necessary facts in the first place. As one treatise has noted:

 

The apparent intent [of CCP section 437c(f)(2)] is to prevent repetitive motions aimed at the same issues. The effect is that a motion for summary judgment, based on issues as to which the court previously denied summary adjudication, is treated similarly to a motion for reconsideration of the order denying summary adjudication

 

(Civil Proc. Before Trial (The Rutter Group) 10:373.2 [italics in original]; see also Bagley v. TRW, Inc. (1999) 73 Cal.App.4th 1092, 1096, fn. 3 [“the prohibition against repeated summary judgment motions was added to make the summary judgment process more efficient and to reduce the opportunities for abuses of the procedure (Sen. Rules Com., Off. of Sen. Floor Analyses, rev. of Sen. Bill No. 2594 (Aug. 23, 1990))”].)

It is settled that a motion for reconsideration based on new facts requires that the moving party must present “a satisfactory explanation for failing to provide the evidence earlier, which can only be described as a strict requirement of diligence.” (Garcia v. Hejmadi (1997) 58 Cal.App.4th 674, 690.) This requirement has not been shown here. Defendant does not allege it had difficulty in tracking down Mr. Postnyy or Mr. Ramirez or in obtaining the testimony contained in their declarations. Nor does Defendant offer any other explanation as to why it could not have submitted these declarations in connection with its prior motion.

 

A second motion for summary adjudication is barred where it offers “no ‘newly discovered facts or circumstances,’” does not suggest that “‘a change of law’” had occurred, and does not request the judge to “make a finding” concerning these statutory requirements. (Bagley, supra, 73 Cal.App.4th at 1093, 1096; see also Schachter v. Citigroup, Inc. (2005) 126 Cal.App.4th 726, 734.) The Court finds Defendant has not demonstrated to the satisfaction of the Court that its instant motion is not barred by Code Civ. Proc. § 437c(f)(2). Defendant does not attempt to make the necessary showing and has not asked the Court to make a finding as to the statutory requirements of Code Civ. Proc. § 437c(f)(2). At most, Defendant shows that it has filed additional evidence responding to the Court’s order denying its prior motion, but such piecemeal adjudication of the sufficiency of Defendant’s evidence is precisely the sort of inefficiency section 437c(f)(2) was enacted to prevent. Accordingly, the Court DENIES Defendant’s motion for summary adjudication as to Issues 1, 2, and 3 concerning Defendant’s claim for breach of the governing documents.

 

The Court notes the same result would follow even if the Court were to consider Defendant’s motion on its merits. Taken together, the declarations of Mr. Postnyy and Mr. Ramirez only provide the requisite factual foundation as to 50 of the 70 citations which form the basis of Defendant’s claim. As the Court explained in denying Defendant’s prior motion, Defendant must demonstrate a sufficient factual foundation as to each of the citations, not just some of them: “While this admission may suffice to demonstrate Melamed breached the parking rules in the Governing Documents on that one occasion, it is only sufficient as to that occasion and not the other 69 notices.” (Order at 7.) As before, Defendant has failed to carry its initial burden in establishing the breaches alleged in its Cross-Complaint. The Court cannot grant Defendant summary adjudication as to a subset of Defendant’s alleged breaches as such a ruling would not dispose of an entire cause of action. (C.C.P. § 437c(f)(1).) This separately warrants the DENIAL of Defendant’s motion for summary adjudication of Issues 1, 2, and 3.

 

            2.         Request for Accommodation

 

Plaintiff’s operative Second Amended Complaint (“SAC”) in consolidated case 18SMCV00086 asserts four causes of action against Defendant for violation of the Fair Housing Act, violation of FEHA, violation of the Unruh Civil Rights Act, and breach of fiduciary duty. Plaintiff alleges he requested parking accommodations from Defendant following a surgery in September 2018 which left him temporarily disabled. Plaintiff alleges he requested this accommodation in correspondence sent to Defendant’s board members dated September 10, 2018, December 7, 2018, and December 18, 2018. (SAC at ¶¶11-13.) Plaintiff alleges Defendant did not offer or provide him with the accommodation he requested. (Id. at ¶15.) This purported failure to accommodate his temporary disability forms the basis of each of the causes of action asserted against Defendant in the SAC. (Id. at ¶¶27; 39, 51, 65.)

 

Plaintiff’s September 2018 correspondence stated, “Just letting you guys know that since my recent surgery I’m physically handicapped and have 24hr visible handicap placard on my front windshield since last w[eek].” (UMF No. 34.) Plaintiff’s December 7, 2018, correspondence stated in pertinent part: “…Also what accommodation does the HOA make for any one who is physically handicapped. How come there is no handicap accessible areas in the entire community? You are still giving me citation w/out making any attempt to accommodate my handicap situation.” (UMF No. 40.) The correspondence dated December 18, 2018—which Defendant states was actually sent on January 4, 2019, not December 18, 2018—argued Plaintiff’s prior correspondence constituted a request for accommodation and included a “formal request” for accommodation:

 

However, if a formal request is what the Association requires, please consider this a formal request for a reasonable accommodation: Dr. Melamed requests that the Association permit any vehicle displaying a handicap placard in the windshield to park in the driveway of 2109 Ridge Drive, Los Angeles, California 90049 (the “Property”). Dr. Melamed further requests that all citations issued since September 10, 2018 be withdrawn, since each citation has been related to vehicles parked in the driveway of the Property that were displaying a handicap placard at the time of the citation.

 

(Ex. 12 to Bernardoni Decl. at 2 [emphasis in original].) Defendant contends none of these letters can be deemed a request for accommodation by Plaintiff.

 

Neither party provides the Court with any authority supporting their own position or disproving the interpretation urged by the other party. Rather, Defendant appears to assert the first two pieces of correspondence were not a request for accommodation because they did expressly state Plaintiff was requesting an accommodation which deviated from the ordinary rules imposed by the governing documents. Plaintiff asserts the correspondence in question should have been understood to be a request for accommodation regardless of the express language used. In the absence of any legal authority on point from which the Court could determine, as a matter of law, whether the correspondence should be deemed a request for accommodation for purposes of Plaintiff’s causes of action, this appears to be a purely factual question to be resolved by the jury.

 

Indeed, Plaintiff has presented evidence showing at least one of Defendant’s board members understood or assumed Plaintiff’s September 2018 correspondence was seeking a parking accommodation. (Ex. 37 to Lamothe Decl. at 46:3-12.) And Plaintiff has presented evidence that the property manager for the development understood Plaintiff’s December 7, 2018, correspondence to be a request for accommodation. (Ex. 39 to Lamothe Decl. at 48:10-17.) The Court thus finds there is a triable issue of material fact as to whether Plaintiff requested a parking accommodation from Defendant for purposes of its causes of action for violation of the Fair Housing Act (Issue 4), violation of FEHA (Issue 5), violation of the Unruh Civil Rights Act (Issue 6), and breach of fiduciary duty (Issue 7) asserted in case 18SMCV00086. Accordingly, Defendant’s motion for summary adjudication of these issues is DENIED.

 

As a separate and independent basis for denying Defendant’s motion, the Court finds Defendant failed to carry its initial burden in demonstrating the correspondence dated December 18, 2019, was not a request for accommodation. Defendant argues this letter was not a request for accommodation because it only requested that Plaintiff be allowed to park in his driveway. Defendant argues Plaintiff has always been permitted to park in his driveway and thus Plaintiff’s request did not require any deviation from the ordinary rules governing where Plaintiff could park. (Motion at 18-19.) The Court disagrees. The letter dated December 18, 2018, does not just request an accommodation in where Plaintiff could park moving forward, it also requested that Defendant withdraw all parking citations issued to Plaintiff since September 10, 2018. (Ex. 12 to Bernardoni Decl. at 2.) Defendant offers no evidence or argument as to this part of Plaintiff’s December 18, 2018, correspondence and thus has not carried its burden in establishing Plaintiff cannot prevail on its causes of action based on the relief requested in this letter. The Court DENIES Defendant’s motion for summary adjudication as to the causes of action asserted by Plaintiff in consolidated case 18SMCV00086.

 

Conclusion

Defendant’s motion for summary adjudication is DENIED.