Judge: John J. Kralik, Case: 23BBCV00658, Date: 2024-01-12 Tentative Ruling

Case Number: 23BBCV00658    Hearing Date: January 12, 2024    Dept: NCB

 

Superior Court of California

County of Los Angeles

North Central District

Department B

 

 

elias reidy,   

 

                        Plaintiff,

            v.

 

eau di nil marketing & events, inc., et al.,    

 

                        Defendants.

 

  Case No.: 23BBCV00658

 

  Hearing Date:  January 12, 2024

 

 [TENTATIVE] order RE:

demurrer/motion to strike

 

BACKGROUND

A.    Allegations

Plaintiff Elias Reidy (“Plaintiff”) alleges that he was an employee of Defendant Eau Di Nil Marketing & Events Inc. (“EDN”), a subsidiary of Defendant Crop King Seeds (“CKS”), and Defendant Landra Deloach (“Deloach”).  Plaintiff alleges that on March 25, 2021 at approximately 10:30 a.m., he was placing cannabis seeds in jars at the EDN factory and, while leaning over his work station, cupping a jar and seeds in both hands, he suddenly felt someone hit him on the right side of the face with great force.  Plaintiff alleges that he was struck with such force that he fell into the left and right side of a cage area before stumbling into the garage area.  Plaintiff alleges that when he looked up, he saw his coworker Defendant Isaiah Vega (“Vega”) standing right behind him, preparing for another attack.  Plaintiff alleges that Vega was wearing large, sharp, metallic rings that caused damage to Plaintiff’s face.  Plaintiff alleges that Vega shouted numerous homophobic, racist, and sexual epithets at him.  He alleges that he pleaded for help, but manager/owner Deloach failed to offer any help or medical assistance. 

            The complaint, filed March 22, 2023, alleges causes of action for: (1) negligence against all Defendants; (2) premises liability against CKS, EDN, and Deloach; (3) assault and battery against CKS, EDN, and Vega; (4) statutory negligence against all Defendants; (5) vicarious liability against CKS, EDN, and Deloach; (6) negligent hiring, supervision, or retention of employee against CKS, EDN, and Deloach; (7) negligence per se against all Defendants; (8) wrongful termination in violation of public policy against CKS, EDN, and Deloach; (9) IIED against all Defendants; and (10) NIED against all Defendants. 

B.     Motion on Calendar

On October 27, 2023, EDN and Deloach filed a demurrer and motion to strike document to the complaint.  The demurrer and motion to strike were filed in a single document.

On November 13, 2023, Plaintiff filed an opposition brief.   

On January 3, 2024, EDN and Deloach filed a reply brief.

DISCUSSION

EDN and Deloach demur to the 1st to 10th causes of action alleged in the complaint on the ground that they fail to state sufficient facts and are uncertain.  They also move to strike Plaintiff’s request for punitive damages.  

A.    1st cause of action for Negligence

The elements of a negligence cause of action are “duty, breach of duty, proximate cause, and damages.”  (Carlsen v. Koivumaki (2014) 227 Cal.App.4th 879, 892.) 

In the 1st cause of action, Plaintiff alleges that on March 25, 2021, Plaintiff was an employee of EDN, a subsidiary of CKS, and Deloach.  (Compl., ¶12.)  He alleges that while he was working, his coworker Vega struck him with his fist, was preparing for another attack, and shouted numerous homophobic, racist, and sexual epithets at him.  (Id., ¶¶13-14.) 

EDN and Deloach demur to the 1st cause of action, arguing that it fails to allege sufficient facts to show that Deloach knew or should have known of any past similar violent crimes of Vega or that they had received any complaints regarding Vega.

The allegations of the negligence cause of action are sparse.  They fail to allege facts regarding EDN and Deloach’s negligence other than that they were Plaintiff’s employer.  As such, it is unclear how this cause of action is any different from a cause of action from the negligent hiring, supervision, and retention cause of action.   Additional facts should be alleged to describe EDN and Deloach’s negligent conduct that caused Plaintiff’s injury.

The demurrer to the 1st cause of action is sustained with leave to amend.

B.     2nd cause of action for Premises Liability

The elements of a premises liability claim and negligence claim are the same: a legal duty of care, breach of that duty, and proximate cause resulting in injury.  (Kesner v. Superior Court (2016) 1 Cal.5th 1132, 1158.)  Those who own, possess, or control property generally have a duty to exercise ordinary care in managing the property in order to avoid exposing others to an unreasonable risk of harm.” (Id.) “A proprietor of premises is not the insurer of the safety of persons on those premises. His duty to control the acts of third persons is a duty of reasonable care to protect against known or reasonably foreseeable risks. He is not required to take precautions against attacks by third persons which he has no reason to anticipate.  (7735 Hollywood Blvd. Venture v. Superior Court (1981) 116 Cal.App.3d 901, 905.) 

In the 2nd cause of action, Plaintiff alleges that Defendants owned, operated, controlled, or were responsible for the subject property on March 25, 2021 and should have foreseen that Plaintiff would be exposed to an unreasonable risk of harm.  (Compl., ¶19.)  Plaintiff alleges that Defendants owed a duty to exercise reasonable and ordinary care in the use, inspection, maintenance, and/or management of the subject property to avoid exposing persons like Plaintiff to an unreasonable risk of harm.  (Id., ¶20.)  Plaintiff alleges that Defendants negligently, carelessly, and recklessly owned, controlled, managed, inspected, and maintained the subject property, so as to proximately cause injuries to Plaintiff.  (Id., ¶21.) 

EDN and Deloach demur to the 2nd cause of action, arguing that Plaintiff only alleges that Defendants negligently owned the property but do not allege further facts to justify a premises liability claim. 

The complaint alleges in the general introductory facts that Plaintiff was attacked by Vega while he was on EDN and Deloach’s premises.  (See Compl. at pp.2-4.)  However, these allegations are not included in the 2nd cause of action.  In order to clarify the pleading so that Defendants are on notice of what specific allegations are being alleged against them in the 2nd cause of action, Plaintiff should allege facts regarding the attack in the 2nd cause of action (as well as any other premises liability claims) upon amendment.  In addition, for the “Introduction” facts in the complaint on pages 2-4, Plaintiff should number the allegations with consecutive paragraph numbers so that they may be easily referenced and cited.

The demurrer to the 2nd cause of action is sustained with leave to amend.

C.     3rd cause of action for Assault and Battery

“The elements of a cause of action for battery are: (1) the defendant touched the plaintiff, or caused the plaintiff to be touched, with the intent to harm or offend the plaintiff; (2) the plaintiff did not consent to the touching; (3) the plaintiff was harmed or offended by the defendant's conduct; and (4) a reasonable person in the plaintiff's position would have been offended by the touching.”  (Carlsen v. Koivumaki (2014) 227 Cal.App.4th 879, 890.)  The elements of a cause of action for assault are: (1) the defendant acted with intent to cause harmful or offensive contact, or threatened to touch the plaintiff in a harmful or offensive manner; (2) the plaintiff reasonably believed he was about to be touched in a harmful or offensive manner or it reasonably appeared to the plaintiff that the defendant was about to carry out the threat; (3) the plaintiff did not consent to the defendant's conduct; (4) the plaintiff was harmed; and (5) the defendant's conduct was a substantial factor in causing the plaintiff's harm.”  (Id.)

In the 3rd cause of action, Plaintiff alleges that he was an employee of EDN and Deloach.  (Compl., ¶25.)  He alleges that Vega attacked him, prepared for another attack, and shouted at him.  (Id., ¶¶26-27.)  The 3rd cause of action is directed against EDN, CKS, and Vega.

The allegations of the 3rd cause of action fail to allege facts showing how EDN engaged in assault and battery.  EDN appears to be a corporate entity.  (See Compl. at p.1.)  Further, the complaint fails to include any facts showing that EDN intentionally touched Plaintiff with intent to cause Plaintiff harm or that it acted with an intent to cause Plaintiff a harmful or offensive contact.

In opposition, Plaintiff provides the law regarding the elements of assault and battery but provides no argument in response to Defendants’ demurrer arguments on the 3rd cause of action.  As Plaintiff has not offered any argument in response to the demurrer on this cause of action or showed how, upon amendment, he can add facts to allege assault and battery against EDN, the demurrer to the 3rd cause of action is sustained without leave to amend as alleged against EDN. 

D.    4th cause of action for Statutory Negligence

In the 4th cause of action, Plaintiff alleges that that unfair competition law pursuant to Business & Professions Code, § 17200 et seq. protects consumers and competitors.  (Compl., ¶31.)  Plaintiff alleges that Defendants’ acts and practices constitute unlawful or unfair business practices.  (Id., ¶32.)  Plaintiff alleges that Defendants’ practices against Plaintiff caused him to suffer damages in a sum not yet ascertained and that he seeks restitution.  (Id., ¶¶34-35.)

EDN and Deloach argue that this cause of action lacks merit because Plaintiff has not identified what law Defendants violated or how this cause of action applies to the facts of this case. Based on the Court’s reading of the complaint, the complaint appears to be about an attack that occurred on EDN and Deloach’s premises.  There are no allegations that Plaintiff was a consumer that was subjected to Defendants’ unfair, unlawful, or fraudulent business practices that caused him damages as a consumer.  Rather, he alleges he was an employee that was attacked on the premises. 

            In opposition, Plaintiff provides the elements of a negligence claim in a single sentence but does not make any further argument about negligence (or “statutory negligence”), nor make any arguments about unfair competition law.  It appears unlikely that Plaintiff will be able to amend this cause of action to state a viable claim for unfair competition or “statutory negligence.”  As such, the demurrer to the 4th cause of action is sustained without leave to amend as to EDN and Deloach. 

E.     5th cause of action for Vicarious Liability

“[A]n employer is vicariously liable for the torts of its employees committed within the scope of the employment.”  (Lisa M. v. Henry Mayo Newhall Memorial Hospital (1995) 12 Cal.4th 291, 296.)  An employer may be vicariously liable for an employee’s torts if the employee’s act was an “outgrowth” of his employment, inherent in the working environment, typical of or broadly incidental to the employer’s business, or, in a general way, foreseeable from the employee’s duties.  (Id. at 298.)  The employer’s liability extends beyond its actual or possible control of the employee, and includes risks inherent to or created by the employee.  (Purton v. Marriott Int’l, Inc. (2013) 218 Cal.App.4th 499, 505.) 

In the 5th cause of action, Plaintiff alleges that on March 25, 2021, Vega was an agent or employee of EDN, CKS, and Deloach.  (Compl., ¶39.)  He alleges that Vega was acting within the scope of his agency/employment when he harmed Plaintiff, such that they are responsible for Plaintiff’s injury.  (Id., ¶¶40-41.) 

EDN and Deloach argue that Plaintiff has not alleged sufficient facts showing that Vega was acting within the scope of his employment at the time of the altercation.  While the complaint alleges that Vega was an agent or employee of EDN, CKS, and Deloach. There are no allegations from which the Court could infer that employment in a marijuana retailer inherently increases the risk of violence by employees. Without more, the allegations for vicarious liability are lacking.  As this is the first attempt at the pleading, the Court will allow Plaintiff leave to amend the 5th cause of action to add facts against EDN and Deloach.

The demurrer to the 5th cause of action is sustained with leave to amend.

F.      6th cause of action for Negligent Hiring, Supervision, or Retention of Employee

California law permits Plaintiff to plead that an employer is liable to him for negligently hiring, supervising, or retaining an unfit employee.  (Doe v. Capital Cities (1996) 50 Cal.App.4th 1038, 1054.)  The employer’s liability is based upon facts showing that the employer knew or should have known that hiring the employee created a particular risk or hazard and that particular harm materializes.  (Id.)

In the 6th cause of action, Plaintiff alleges that EDN, CKS, and Deloach hired Vega, but that he was unfit or incompetent to perform the work for which he was hired.  (Compl., ¶¶46-47.)  He alleges that EDN and CKS knew or should have known that Vegas was unfit or incompetent and that this created a particular risk to others and did cause harm to Plaintiff.  (Id., ¶¶48-49.) 

            At most, Plaintiff alleges that Vega was unfit or incompetent to perform the work he was hired to perform—i.e., the business of EDN, CKS, and Deloach regarding cannabis.  There are no allegations regarding his unfitness or incompetence that would have proximately caused Plaintiff’s injury.  There are also no allegations that EDN and CKS knew or should have known of facts that hiring Vega would have created a particular risk or hazard, such as violent propensities. 

            For these reasons, the demurrer to the 6th cause of action is sustained with leave to amend.

G.    7th cause of action for Negligence Per Se

“[T]he doctrine of negligence per se is not a separate cause of action, but creates an evidentiary presumption that affects the standard of care in a cause of action for negligence.”  (Millard v. Biosources, Inc. (2007) 156 Cal.App.4th 1338, 1353 at fn.2; see also Turner v. Seterus, Inc. (2018) 27 Cal.App.5th 516, 543.  Evidence Code § 669 states:

(a) The failure of a person to exercise due care is presumed if:

(1) He violated a statute, ordinance, or regulation of a public entity;

(2) The violation proximately caused death or injury to person or property;

(3) The death or injury resulted from an occurrence of the nature which the statute, ordinance, or regulation was designed to prevent; and

(4) The person suffering the death or the injury to his person or property was one of the class of persons for whose protection the statute, ordinance, or regulation was adopted.

(b) This presumption may be rebutted by proof that:

(1) The person violating the statute, ordinance, or regulation did what might reasonably be expected of a person of ordinary prudence, acting under similar circumstances, who desired to comply with the law; or

(2) The person violating the statute, ordinance, or regulation was a child and exercised the degree of care ordinarily exercised by persons of his maturity, intelligence, and capacity under similar circumstances, but the presumption may not be rebutted by such proof if the violation occurred in the course of an activity normally engaged in only by adults and requiring adult qualifications.

(Evid. Code, § 669.)

This is not an independent cause of action, but an evidentiary presumption.  If Plaintiff seeks to allege negligence per se, he should do so in connection with his 1st cause of action for negligence as an alternate theory.  However, upon the Court’s review of the allegations of the 7th cause of action, it appears unlikely that Plaintiff has a claim for negligence per se against EDN and Deloach.  However, as this is the first attempt at the pleading, the Court will allow Plaintiff limited leave to amend the 7th cause of action for negligence per se to incorporate it into the 1st cause of action for negligence and to add facts showing that the presumption exists. 

The demurrer to the 7th cause of action is sustained with leave to amend as limited herein.

H.    8th cause of action for Wrongful Termination in Violation of Public Policy

“The elements of a claim for wrongful discharge in violation of public policy are (1) an employer-employee relationship, (2) the employer terminated the plaintiff's employment, (3) the termination was substantially motivated by a violation of public policy, and (4) the discharge caused the plaintiff harm.”  (Yau v. Santa Margarita Ford, Inc. (2014) 229 Cal.App.4th 144, 154; see also CACI 2430.)  The public policy implicated “must be: (1) delineated in either constitutional or statutory provisions; (2) 'public' in the sense that it 'inures to the benefit of the public' rather than serving merely the interests of the individual; (3) well established at the time of the discharge; and (4) substantial and fundamental.”  (City of Moorpark v. Superior Court (1998) 18 Cal.4th 1143, 1159.) 

In the 8th cause of action, Plaintiff alleges that on March 25, 2021, EDN, CKS, and Deloach fired Plaintiff in retaliation of him complaining of unsafe working conditions and requesting medical leave and treatment following battery at work by Vega during workplace hours.  (Compl., ¶66.)  Plaintiff alleges that they fired him in retaliation for making a police report regarding the attack and failed to provide him with a reasonable accommodation in accordance with the ADA based on his injuries and disabilities sustained on the job.  (Id., ¶¶67-68.) Plaintiff alleges he was wrongfully terminated.  (Id., ¶69.) 

EDN and Deloach argue that Plaintiff has not alleged the elements of a substantial and fundamental public interest that was violated at the time of discharge.  At most, Plaintiff alleges that he was terminated for complaining about unsafe working conditions and requesting medical leave after the attack.  It is unclear if the unsafe working condition was the single event of Vega’s attack or if there was any other prior unsafe working condition present at the premises.  Also, Plaintiff has not alleged what “public policy” was at issue that was violated at the time of termination.

Nevertheless, the allegation that Plaintiff’s termination constituted retaliation for making a police report (reporting such allegations is a Constitutional right), on its own adequately alleges a termination in violation of public policy. While one can certainly argue that the cause of action should be supported by further facts regarding the other termination theories, the demurrer to the 8th cause of action is overruled.

I.        9th cause of action for IIED

The elements of intentional infliction of emotional distress are: (1) outrageous conduct by the defendant; (2) the defendant’s intention of causing or reckless disregard of the probability of causing emotional distress; (3) the plaintiff suffered severe or extreme emotional distress; and (4) the plaintiff’s injuries were actually and proximately caused by the defendant’s outrageous conduct.  (Vasquez v. Franklin Mgmt. Real Estate Fund, Inc. (2013) 222 Cal.App.4th 819, 832.)  In order to avoid a demurrer, the plaintiff must allege with great specificity, the acts which she believes are so extreme as to exceed all bounds of behavior usually tolerated in a civilized community.  (Id.)

Conduct to be outrageous must be so extreme as to exceed all bounds of behavior usually tolerated in a civilized community.  (Christensen v. Superior Court (1991) 54 Cal.3d 868, 903.)  In addition, the outrageous conduct must be of a nature which is especially calculated to cause, and does cause, mental distress of a very serious kind.  (Id.)  “Although emotional distress may consist of any highly unpleasant mental reaction such as fright, grief, shame, humiliation, embarrassment, anger, chagrin, disappointment or worry [citation], to make out a claim, the plaintiff must prove that emotional distress was severe and not trivial or transient.”  (Wong v. Tai Jing (2010) 189 Cal.App.4th 1354, 1376.)  Such distress must be “of such substantial quality or enduring quality that no reasonable person in civilized society should be expected to endure it.”  (Potter v. Firestone Tire & Rubber Co. (1993) 6 Cal.4th 965, 1004.)

In the 9th cause of action, Plaintiff alleges that Defendants owed him a duty of care not to cause him emotional distress and that they knowingly harassed Plaintiff based on his disability of sex and gender.  (Compl., ¶¶74-75.)  Plaintiff alleges that Defendants were aware of treating him in this manner deprived him of his livelihood.  (Id., ¶76.)  He alleges that Defendants’ discriminatory, harassing, and retaliatory actions constituted severe and outrageous misconduct and caused him to suffer emotional distress.  (Id., ¶78.) 

The complaint fails to allege specific facts about how EDN and Deloach engaged in extreme and outrageous conduct against Plaintiff that caused him to suffer severe emotional distress.  As currently alleged, the facts generally allege that they owed him a duty and caused him emotional distress, but specific facts on what actions they engaged in and how such actions caused him to suffer severe emotional distress have not been alleged.

The demurrer to the 9th cause of action is sustained with leave to amend.

J.       10th cause of action for NIED

An NIED claim is not an independent tort, but the tort of negligence.  (McMahon v. Craig (2009) 176 Cal.App.4th 1502, 1509.)  A cause of action for NIED may be brought under two general instances: (1) where Plaintiff is a bystander and seeks to recover damages as percipient witness to the injury of another; or (2) where Plaintiff is a direct victim in that the emotional distress damages result from a duty owed the plaintiff that is assumed by defendant or imposed on the defendant as a matter of law, or that arises out of the relationship between the two.  (Id. at 1509-10.)  “A defendant may be liable in tort for negligently inflicting emotional distress on persons to whom the defendant owes a duty of care.  That duty can have three alternative origins: (1) a duty imposed on the defendant by law, (2) a duty assumed by the defendant, or (3) a duty arising out of a preexisting relationship between plaintiff and defendant.”  (Benson v. Superior Court (2010) 185 Cal.App.4th 1179, 1187.) 

The 10th cause of action alleges similar facts as the IIED cause of action.  (See Compl., ¶¶85-88.)  However, for the same reasons as discussed above, it is unclear what actions Defendants took that breached their duties against Plaintiff for an NIED claim.  As such, the demurrer to the 10th cause of action is sustained with leave to amend.

K.    Motion to strike allegations for Punitive Damages

EDN and Deloach move to strike allegations for punitive damages in the complaint.  Punitive damages are sought in connection with the 8th, 9th, and 10th causes of action.  (Compl., ¶¶71, 82, 90.)

In light of the ruling on the demurrer to the 9th and 10th causes of action, the motion to strike the allegations for punitive damages with respect to the 9th and 10th causes of action is moot.

A complaint including a request for punitive damages must include allegations showing that the plaintiff is entitled to an award of punitive damages.  (Clauson v. Superior Court (1998) 67 Cal.App.4th 1253, 1255.)  A claim for punitive damages cannot be pleaded generally and allegations that a defendant acted "with oppression, fraud and malice" toward plaintiff are insufficient legal conclusions to show that the plaintiff is entitled to an award of punitive damages.  (Brousseau v. Jarrett (1977) 73 Cal.App.3d 864, 872.)  Specific factual allegations are required to support a claim for punitive damages.  (Id.)

Civil Code § 3294 authorizes a plaintiff to obtain an award of punitive damages when there is clear and convincing evidence that the defendant engaged in malice, oppression, or fraud.  Section 3294(c) defines the terms in the following manner:

(1)   "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.

(2)   "Oppression" means despicable conduct that subjects a person to cruel and unjust hardship in conscious disregard of that person's rights.

(3)   "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. 

With respect to a corporate employer, section 3294(b) requires that the advance knowledge and conscious disregard, authorization, ratification or act of oppression, fraud, or malice must be on the part of an officer, director, or managing agent of the corporation.

In the 8th cause of action for wrongful termination in violation of public policy, Plaintiff alleges that Defendants’ actions were taken by and through their managing agents, officers, or directors and that such conduct was engaged in through a deliberate, cold, callous, fraudulent, and intentional manner in order to injure and damage Plaintiff or in conscious disregard to his rights.  (Compl., ¶71.)  The allegations of the 8th cause of action are summarized more fully above in the demurrer analysis.

The Court finds that the allegations are conclusory and lack the specificity and particularity required to allege punitive damages.  While Plaintiff has essentially alleged the words of the statute, more facts are required to allege punitive damages.  As such, the motion to strike is granted with leave to amend. 

CONCLUSION AND ORDER                                     

            Defendants Eau Di Nil Marketing & Events Inc. and Landra Deloach’s demurrer to the complaint is sustained with 20 days leave to amend as to the 1st, 2nd, 5th, 6th, 7th, 9th, and 10th causes of action; sustained without leave to amend as to the 3rd and 4th causes of action; and overruled as to the 8th cause of action.

            The motion to strike the allegations for punitive damages is granted with 20 days leave to amend.

Defendants shall provide notice of this order.

 

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DATED: January 12, 2024                                         ___________________________

                                                                              John Kralik

                                                                              Judge of the Superior Court