Judge: Joseph Lipner, Case: 21STCV37974, Date: 2023-11-09 Tentative Ruling

Case Number: 21STCV37974    Hearing Date: December 5, 2023    Dept: 72

 

SUPERIOR COURT OF CALIFORNIA

COUNTY OF LOS ANGELES

 

DEPARTMENT 72

 

TENTATIVE RULING

 

WEST CASITAS, LLC,

 

                                  Plaintiff,

 

         v.

 

 

SWING HOUSE STAGES, INC.,

 

                                  Defendant.

 

 Case No:  21STCV37974

 

 

 

 

 

 Hearing Date:  December 5, 2023

 Calendar Number:  5

 

 

 

Plaintiff West Casitas, LLC (“Plaintiff”) moves for summary judgment and summary adjudication on its cause of action against Defendant Swing House Stages, Inc. (“Defendant”) for breach of lease and on all of Defendant’s affirmative defenses.

 

Plaintiff’s motion is for summary judgment is GRANTED.

 

Plaintiff’s motion for summary adjudication is DENIED AS MOOT.

 

Background

 

Plaintiff is the owner of the property located at 3229 Casitas Avenue, Los Angeles, California 90039 (the “Property”). (Stauffer Decl. ¶ 2.) Elite Property Management, LLC (“Elite”) has managed the property on Plaintiff’s behalf since September 2019. (Stauffer Decl. ¶ 1.)

 

On February 18, 2014, Plaintiff and Defendant entered into a written lease (the “Lease”) under which Defendant would rent the Property from Plaintiff. (Stauffer Decl. ¶ 3; Compendium of Exhibits (“Compendium”), Exh. 1 (the “Lease”).) The Lease provides for a term of 10 years, beginning February 18, 2014, and ending February 17, 2024.  (Lease at p. 8 [page numbers in the Compendium refer to the overall page number in the PDF file].) Starting on February 18, 2020, the monthly base rent under the lease was $28,500. (Lease at 8.)

 

Beginning in April 2020, Defendant began to fail to make its full monthly base rent payments. (Stauffer Decl. ¶ 4.) The final payment that Defendant made on the lease was a partial payment of one half of the monthly rent in July 2021. (Stauffer Decl. ¶ 4.) Failure to pay rent when due constitutes a default on the Lease. (Lease at p. 21.)

 

From around October 2020 to October 2021, Plaintiff, Elite, and Defendant attempted to come to an agreement under which Plaintiff would pay the missing rent, but they reached no agreement. (Stauffer Decl. ¶¶ 9-30.)

 

Plaintiff filed this action against Defendant on October 14, 2021, alleging one cause of action for breach of lease.

 

On February 3, 2022, Elite sent Defendant a Notice of Default under the lease, requesting payment of $545,473.12 within seven days. (Beskind Decl. ¶ 3; Compendium, Exh. 18.) Defendant did not make any payments in response to the notice. (Beskind Decl. ¶ 3.)

 

On May 6, 2022, Defendant filed an Answer, which contained a general denial as well as over thirty affirmative defenses. Around the same time, Defendant and Genoveva Winsen (“Winsen”) filed a cross-complaint against Plaintiff and several other parties, which has since been fully disposed of in two separate summary judgment motions.

 

On February 17, 2023, Plaintiff filed a separate action for unlawful detainer in the Los Angeles County Superior Court. (Stauffer Decl. ¶ 32.) The eviction action was resolved in part by a settlement dated March 23, 2023, which resolved the issue of possession but provided that it did not encompass any claims for damages. (Stauffer Decl. ¶ 33.)

 

On April 20, 2023, Elite sent Defendant a further Notice of Default, requesting payment of $830,738.10 within seven days. (Beskind Decl. ¶ 4.; Compendium Exh. 24.) The amount requested reflected the amount owed by Defendant under the lease as of January 31, 2023 and did not include late fees or interest. (Beskind Decl. ¶ 4.; Compendium Exh. 24.) Defendant once again did not make any payments in response to the notice. (Beskind Decl. ¶ 4.)

 

In total, Plaintiff missed $840,738.10 in rent payments. (Stauffer Decl. 4-7; Ledger at pp. 63-64.)

 

 

 

 

 

 

 

Plaintiff filed this motion on May 3, 2023. Defendant filed no opposition was filed.

 

Legal Standard

 

The purpose of a motion for summary judgment or summary adjudication “is to provide courts with a mechanism to cut through the parties’ pleadings in order to determine whether, despite their allegations, trial is in fact necessary to resolve their dispute.” (Aguilar v. Atlantic Richfield Co. (2001) 25 Cal.4th 826, 843.) “Code of Civil Procedure section 437c, subdivision (c), requires the trial judge to grant summary judgment if all the evidence submitted, and ‘all inferences reasonably deducible from the evidence’ and uncontradicted by other inferences or evidence, show that there is no triable issue as to any material fact and that the moving party is entitled to judgment as a matter of law.” (Adler v. Manor Healthcare Corp. (1992) 7 Cal.App.4th 1110, 1119.) 

“In ruling on the motion, the court must consider all of the evidence and all of the inferences reasonably drawn therefrom [citation] and must view such evidence [citations] and such inferences [citations] in the light most favorable to the opposing party.” (Aguilar, supra, at pp. 844-845 [quotation marks omitted].) 

“A plaintiff or cross-complainant has met his or her burden of showing that there is no defense to a cause of action if that party has proved each element of the cause of action entitling the party to judgment on the cause of action. Once the plaintiff or cross-complainant has met that burden, the burden shifts to the defendant or cross-defendant to show that a triable issue of one or more material facts exists as to the cause of action or a defense thereto. The defendant or cross-defendant shall not rely upon the allegations or denials of its pleadings to show that a triable issue of material fact exists but, instead, shall set forth the specific facts showing that a triable issue of material fact exists as to the cause of action or a defense thereto.” (Code Civ. Proc. § 437c, subd. (p)(1); see also Aguilar, supra, 25 Cal.4th at p. 849.)

“Once the [moving party] . . . has met that burden, the burden shifts to the [nonmoving party] . . . to show that a triable issue of one or more material facts exists as to the cause of action or a defense thereto.” (Ibid.) To establish a triable issue of material fact, the party opposing the motion must produce substantial responsive evidence. (Sangster v. Paetkau (1998) 68 Cal.App.4th 151, 166.) “If the [nonmoving party] cannot do so, summary judgment should be granted.” (Avivi v. Centro Medico Urgente Medical Center (2008) 159 Cal.App.4th 463, 467.) 

 

 

Discussion

 

Here, Defendant does not oppose the motion for summary judgment. As such, the Court evaluates Plaintiff’s showing in its moving papers  to determine whether Plaintiff has made a prima facie showing that there are no triable issues of fact

 

Breach of Lease

 

To prove a cause of action for breach of contract, Plaintiff must be able to establish “(1) the existence of the contract, (2) plaintiff’s performance or excuse for nonperformance, (3) defendant’s breach, and (4) the resulting damages to the plaintiff.” (Oasis West Realty, LLC v. Goldman (2011) 51 Cal.4th 811, 821.)

 

Plaintiff has shown the existence of the lease. Plaintiff has authenticated the lease through the declaration of Jeff Stauffer. (Stauffer Decl. ¶¶ 1, 3.) Furthermore, Defendant admitted the authenticity of the Lease and that it is the tenant on the Lease in its responses to requests for admissions. (Compendium, Exh. 20 at pp. 290, 294-295.)

 

Plaintiff has shown that it performed on the lease. Defendant was in possession of the Property during the period between January 1, 2020 and January 31, 2023. (Stauffer Decl. ¶ 8.) In Genoveva Winsen’s PMK deposition on behalf of Defendant, Winsen testified that Defendant was in possession of the Property from January 1, 2020 through the date of the deposition on December 19, 2022. (Compendium, Exh. 22 (“PMK”) at p. 313:14-21.)

 

Plaintiff has shown that Defendant breached the lease. As discussed above, in April 2020, Defendant began to fail to make its full monthly base rent payments. (Stauffer Decl. ¶ 4; Compendium Exh. 2 (“Ledger”) at p. 63.) The final payment that Defendant made on the lease was a partial payment of one half of the monthly rent in July 2021. (Stauffer Decl. ¶ 4; Ledger at pp. 63-64.) As discussed above, Plaintiff sent Defendant multiple notices of default and engaged in protracted negotiations for roughly a year over the possibility of a cure for Defendant’s default, but Defendant never paid the missing rent.

 

Plaintiff has shown that it suffered damages as a result of Defendant’s breach because it is owed $840,738.10 in missing rent payments. (Stauffer Decl. 4-7; Ledger at pp. 63-64.)

 

Therefore, the Court finds that Plaintiff has made a prima facia burden that there are no triable issues of fact and that it has established its cause of action for breach of contract. Because Defendant has not filed an opposition, the Court does not search the record for evidence of disputes of fact, but instead moves on to consideration of whether the affirmative defenses asserted by Defendant bar summary judgment.

 

Affirmative Defenses

 

Civil Procedure Code section 437c, subdivision (p)(1) provides that a plaintiff seeking summary judgment does not initially carry the burden to disprove affirmative defenses. (Ibid.) Rather, a Plaintiff satisfies their initial burden by proving each element of their cause of action. “Once the plaintiff or cross-complainant has met that burden, the burden shifts to the defendant or cross-defendant to show that a triable issue of one or more material facts exists as to the cause of action or a defense thereto.” (Ibid.)

 

          Here, Plaintiff has carried its initial burden and Defendant does not oppose this motion. Thus, it would be appropriate to grant summary judgment without proceeding further. However, out of an abundance of caution, the Court evaluates Defendant’s affirmative defenses below.

 

General Denial

 

A general denial is not an affirmative defense; rather; “[t]he filing of a general denial denies in one sentence all the allegations of the complaint.” (Walsh v. West Valley Mission Community College Dist. (1998) 66 Cal.App.4th 1532, 1545.) Because the Court concludes that Plaintiff has established a prima facie case for its only cause of action, the Court concludes that this defense is not a bar to summary judgment.

 

Covid-19 Moratoria

 

          Defendant alleges in its second and fourth affirmative defenses that the Covid-19 Moratoriums bar the lawsuit.

 

          During the Covid-19 pandemic, Los Angeles County issued a temporary rent moratorium. (See generally Compendium, Exh. 5.) The protections applied to commercial tenants during the “Protected Time Period” of March 4, 2022 through January 31, 2022, during which the tenant was unable to pay rent due to “Financial Impacts Related to COVID-19.” (Compendium, Exh. 5 at pp. 83-84.)

 

          The resolution more broadly provided for a “Protections Period,” formerly known as the “Moratorium Period,” which lasted from March 4, 2020 to March 31, 2023. (Compendium, Exh. 5 at p. 84.)

 

          The resolution did not forgive commercial tenants’ rent obligations; rather, it provided that “[u]npaid rent incurred during the Protections Period shall be repaid pursuant to the following …. (a) Commercial Tenants with nine (9) employees or fewer shall have until January 31, 2023 to repay unpaid rent incurred during the Protected Time Period” and “Commercial Tenants with ten (10) or more, but fewer than 100, employees shall have until July 31, 2022 to repaid unpaid rent incurred during the Protected Time Period …” (Compendium, Exh. 5 at p. 91.)

 

          Thus, any rent that Defendant could have validly deferred due to the moratorium would still be owed by this time.

 

          Similarly, Defendant could not assert the City of Los Angeles’s commercial eviction moratorium, formerly codified at Section 49.99.3 of the Los Angeles City Municipal Code, as a defense. Section 49.99.3 was repealed in full in January of 2023. (City of Los Angeles Muni. Code § 49.99.3.)

 

          Furthermore, there are no facts showing that Defendant was actually unable to pay rent due to Covid-19-related financial impacts. Thus, it appears that Defendant was never protected by these moratoria in the first place.

         

The Court therefore concludes that this defense is not a bar to summary judgment.

 

          Additionally, Defendant alleges that the Covid-19 moratoria bar a receivership. Plaintiff does not seek a receivership, so this defense does not apply. The Court therefore concludes that that defense is not a bar to summary judgment.

 

Accounting

 

An action for accounting is equitable in nature and may be brought were “(1) where a fiduciary relationship exists between the parties, or (2) where, even though no fiduciary relationship exists, the accounts are so complicated that an ordinary legal action demanding a fixed sum is impracticable.” (Los Defensores, Inc. v. Gomez (2014) 223 Cal.App.4th 377, 401.)

 

Defendant alleges that an accounting is necessary to determine whether any of the damages Plaintiff seeks include interest fees or late charges accrued during the Covid-19 moratoria.

 

First, Plaintiff was not Defendant’s fiduciary. The Answer alleges no specific basis for a fiduciary relationship. Further, California law does not recognize a general fiduciary relationship that arises out of commercial relationships. (Girard v. Delta Towers Joint Venture (1993) 20 Cal.App.4th 1741, 1749; (Martin v. U-Haul Co. of Fresno (1988) 204 Cal.App.3d 396, 412 [“California courts have not extended the 'special relationship' doctrine to include ordinary commercial contractual relationships”].)

 

Second, the undisputed facts show that the damages sought do not include any interest fees or late charges on the unpaid rent. (Ledger at pp. 63-64; Stauffer Decl. ¶¶ 4-7.)

 

Because the undisputed facts show that no basis to demand an accounting exists, the Court concludes that this defense is not a bar to summary judgment.

 

                    Excuse

 

Defendant alleges in its 5th and 22nd affirmative defenses that any breach by Defendant of the Lease was induced by Plaintiff, and consequently excused.

“Covenants in leases are held to be mutually independent unless the lease expressly or impliedly makes them conditional.” (Goldsmith v. Tub-O-Wash (1962) 199 Cal.App.2d 132, 138.) Thus, “liability under the lease continues as long as the lessee continues in possession.” (Grace v. Croninger (1936) 12 Cal.App.2d 603, 606.)

 

As discussed above, Plaintiff repeatedly attempted to obtain the missing rent from Defendant, including attempting to negotiate a payment plan for Defendant, and therefore did not directly induce nonpayment. (Stauffer Decl. ¶¶ 9-30.) Defendant has always attributed its inability to pay rent to the “COVID-19 Pandemic and closure of [its] business by State and local authorities,” and not to any action by Plaintiff. (Cross-Complaint ¶ 115.) Defendant was in possession of the Property during the period between January 1, 2020 and January 31, 2023. (Stauffer Decl. ¶ 8.) Furthermore, there are no disputed or undisputed facts showing that Defendant breached the lease or otherwise induced nonpayment. Thus, Defendant was required to pay rent during its nonpayment.

 

The Court concludes that this defense is not a bar to summary judgment.

 

                    Consent

 

Defendant alleges that Plaintiff consented to the breach. As discussed above, Plaintiff repeatedly attempted to obtain the missing rent from Plaintiff. (Stauffer Decl. ¶¶ 9-30.) The Court therefore concludes that this defense is not a bar to summary judgment.

 

                    Preponderance of the Equities

 

As discussed above, the undisputed facts show that Defendant not only breached its lease with Plaintiff but failed to cure the breach despite being given many opportunities and over a year to do so. These facts show that the equities favor Plaintiff. Furthermore, there are no facts which may indicate that the equities in this case favor Defendant. The Court therefore concludes that this defense is not a bar to summary judgment.

 

                    Commercial Impracticability

 

“Impossibility is defined as not only strict impossibility but [also] impracticability because of extreme and unreasonable difficulty, expense, injury, or loss involved.” (SVAP III Poway Crossings, LLC v. Fitness International, LLC (2023) 87 Cal.App.5th 882, 893 [internal quotations and citations omitted].) “There is no impossibility of performance where one party has rendered services as agreed and nothing remains for the other party to do but pay the agreed compensation.” (Browne v. Fletcher Aviation Corp. (1945) 67 Cal.App.2d 855, 862.)

 

Defendant attributes its inability to pay rent to the “COVID-19 Pandemic and closure of [its] business by State and local authorities.” (Cross-Complaint ¶ 115.)

 

In Fitness International, the court rejected a commercial tenant’s assertion of the impracticability doctrine even though the tenant was subject to pandemic related closure orders because “[t]he government closure orders did not make it illegal for [the tenant] to pay rent.” (SVAP III Poway Crossings, LLC v. Fitness International, LLC, supra, 87 Cal.App.5th at p. 893.)

 

These facts are nearly identical to those in Fitness International. Thus, the Court concludes that this defense is not a bar to summary judgment.

 

                    Unclean Hands

 

Unclean hands “has been applied in equity suits to prevent a finding of merit in situations where one of the parties planned and executed fraud or inequitable devices to obtain an improper advantage over the other side.” (Delfino v. Delfino (1969) 272 Cal.App.2d 556, 562.) “Whether the particular misconduct is a bar to the alleged claim for relief depends on (1) analogous case law, (2) the nature of the misconduct, and (3) the relationship of the misconduct to the claimed injuries.” (East West Bank v. Rio School Dist. (2015) 235 Cal.App.4th 742, 751.) When “there is no analogous case law supporting the application of the unclean hands defense to the facts present,” “[t]hat finding alone is sufficient to warrant the denial of the defense.” (Ibid.)

 

Here, Defendant has not identified any analogous case law applying the doctrine of unclean hands to a landlord seeking recovery of rent under similar facts. Furthermore, the undisputed facts do not show that Plaintiff engaged in any misconduct. Plaintiff did not charge any late fees or interest as required by the Covid-19 moratorium, and Plaintiff has already obtained summary judgment on the cross-claims raised against it by Defendant. Further, Defendant has always attributed its inability to pay rent to the “COVID-19 Pandemic and closure of [its] business by State and local authorities,” and not to any action by Plaintiff. (Cross-Complaint ¶ 115.)

 

Thus, the Court concludes that this defense is not a bar to summary judgment.

 

                    Statute of Limitations and Laches

 

The statute of limitations for contract actions is four years. (Code Civ. Proc., § 337, subd. (a).)

 

Here, Defendant’s failure to pay the full rent began in April 2020. (Stauffer Decl. ¶ 6-7; see also Ledger at pp. 63-64.) Plaintiff filed this action against Defendant on October 14, 2021. Thus, Plaintiff brought the action within the statute of limitations.

 

“The doctrine of laches is to actions in equity what statutes of limitations are to actions in law.” (In re Marriage of Parker (2017) 14 Cal.App.5th 681, 687.) Thus, the applicable timeliness analysis in this breach of contract action is conducted below under the Statute of Limitations defense.

 

Furthermore, because the Court finds below that Plaintiff brought this action within the applicable statute of limitations, Plaintiff did not unreasonably delay, as a matter of law. (David Welch Co. v. Erskine & Tulley (1988) 203 Cal.App.3d 884, 893 [suit brought well within the statute of limitations not barred by laches], disapproved of on other grounds by Lee v. Hanley (2015) 61 Cal.4th 1225.)

 

The court therefore concludes that these defenses do not bar summary judgment.

 

                    Failure to Mitigate

 

Civil Code section 1951.2 limits a landlord’s ability to recover damages where a tenant breaches a lease by abandoning the property before the end of the lease if the landlord does not make a reasonable and good-faith effort to mitigate the damages. (Civ. Code, § 1951.2.)

 

Here, however, Plaintiff’s damages occurred prior to Defendant’s vacation of the Property, and resulted not from Defendant’s lack of a tenant at all, but from Plaintiff’s failure to pay rent while it was still in possession of the property. The lease did not terminate until February 9, 2023. (Stauber Decl. ¶ 25.) All of Plaintiff’s damages accrued before then. (Stauffer Decl. 4-7; Ledger at pp. 63-64.)

 

Thus, the duty to mitigate does not apply here and the Court concludes that this defense is not a bar to summary judgment.

 

Frustration of Purpose

 

The doctrine of commercial frustration applies where “[p]erformance remains entirely possible, but the whole value of the performance to one of the parties at least, and the basic reason recognized as such by both parties, for entering into the contract has been destroyed by a supervening and unforeseen event.” (Dorn v. Goetz (1948) 85 Cal.App.2d 407, 410 [internal quotations and citations omitted].) A party raising frustration of purpose must show that “the value of counterperformance is totally or nearly totally destroyed, for frustration is no defense if it was foreseeable or controllable by the promisor, or if counterperformance remains valuable.” (Lloyd v. Murphy (1944) 25 Cal.2d 48, 54.) “[L]aws or other governmental acts that make performance unprofitable or more difficult or expensive do not excuse the duty to perform a contractual obligation.” (Id. at 55.)

 

Defendant attributes its inability to pay rent to the “COVID-19 Pandemic and closure of [its] business by State and local authorities.” (Cross-Complaint ¶ 115.)

 

Here, Defendant remained in possession of the premises from January 1, 2020 to January 31, 2023. (Stauffer Decl. ¶ 8.) Although there were Covid-19-related government restrictions on some business activity during that time period, government restrictions are not covered by the frustration of purpose defense. (Lloyd, supra, 25 Cal.2d at p. 54.) Furthermore, the Covid-19 restrictions, and the pandemic as a whole, only lasted a few years out of a 10-year lease. Because the undisputed facts show that the value of Defendant’s performance was not totally (or nearly totally) destroyed, summary judgment on this defense is appropriate.

 

Furthermore, the legal effect of frustration of purpose is the immediate termination of the contract. (Johnson v. Atkins (1942) 53 Cal.App.2d 430, 433.) Here, Defendant remained in possession of the Property throughout 2020 and 2021. (Stauffer Decl. ¶ 8.) In SVAP III Poway Crossings, LLC v. Fitness International, LLC, supra, 87 Cal.App.5th at p. 893, the court found that a commercial tenant could not establish frustration defense based on pandemic closure orders because it “continued to occupy the premises throughout the closure periods and did not attempt to rescind the lease.” (Ibid.) Because the same facts are true here, Defendant cannot show frustration of purpose as a matter of law.

 

Novation

 

Defendant conceded in response to Plaintiff’s interrogatory that there was no novation of the lease. (Compendium, Exh. 19 at p. 284 [Form Interrogatory 50.4: “Was any agreement alleged in the pleadings terminated by mutual agreement, release, accord and satisfaction, or novation?” A: “No.”] The Court therefore concludes that this defense is not a bar to summary judgment.

 

                    Offset

 

Where a judgment debtor has a claim of their own against the judgment creditor, the claims may be set off against each other. (Erlich v. Superior Court of Los Angeles County (1965) 63 Cal.2d 551, 556.)

 

Here, the Court has already granted summary judgment on each of Defendant’s cross-claims against Plaintiff, so there is no potential judgment to set off against Plaintiff’s claims. The Court therefore concludes that this defense is not a bar to summary judgment.

 

                    Accord and Satisfaction

 

Defendant conceded in response to Plaintiff’s interrogatory that there was no accord and satisfaction of the lease. (Compendium, Exh. 19 at p. 284 [Form Interrogatory 50.4: “Was any agreement alleged in the pleadings terminated by mutual agreement, release, accord and satisfaction, or novation?” A: “No.”] The Court therefore concludes that this defense is not a bar to summary judgment.

 

                    Estoppel

 

“The elements of equitable estoppel are (1) the party to be estopped must be apprised of the facts; (2) he must intend that his conduct shall be acted upon, or must so act that the party asserting the estoppel has a right to believe it was so intended; (3) the other party must be ignorant of the true state of facts; and (4) he must rely upon the conduct to his injury.” (Schafer v. City of Los Angeles (2015) 237 Cal.App.4th 1250, 1261 [internal quotations and citations omitted].)

 

Here, there are no facts, disputed or undisputed, that suggest that Plaintiff acted in a way such as to induce reliance by Defendant, or that any such reliance was detrimental. The parties entered the Lease in February, 2014, long before the Covid-19 pandemic. (Stauffer Decl. ¶ 3; see also the Lease.) Defendant has always attributed its inability to pay rent to the “COVID-19 Pandemic and closure of [its] business by State and local authorities,” and not to any action by Plaintiff. (Cross-Complaint ¶ 115.) When Defendant stopped paying rent, Plaintiff did not induce Defendant to continue its nonpayment, but rather sought to set up a payment plan under which Plaintiff would be able to repay the rent. (Stauffer Decl. ¶¶ 9-30.) Even assuming arguendo that this is the conduct that Defendant believes induced reliance, Defendant could not reasonably have interpreted these acts as a reason to continue nonpayment of rent, and furthermore, there are no facts of which Plaintiff was aware and Defendant was not that led to the harm in question. The doctrine of estoppel appears inapplicable to the facts of this case. The Court concludes that this defense is not a bar to summary judgment.

 

                    Unjust Enrichment

 

Defendant alleges that Plaintiff has been unjustly enriched by engaging in discrimination, harassment, retaliation, and intimidation and by charging late fees and interest in violation of the Covid-19 moratoria.

 

As discussed above, the undisputed facts show that the damages sought do not include any interest fees or late charges on the unpaid rent. (Ledger at pp. 63-64; Stauffer Decl. ¶¶ 4-7.)

 

Unjust enrichment exists when a person has received money or its equivalent under such circumstances that in equity and good conscience they ought not to retain it. (Philpott v. Superior Court in and for Los Angeles County (1934) 1 Cal.2d 512, 523.) Thus, discrimination, harassment, retaliation, and intimidation are legally insufficient to establish unjust enrichment. Furthermore, to the extent that these allegations refer to the allegations raised in Defendant’s cross-complaint, the Court has already granted summary judgment against those allegations.

 

The Court therefore concludes that this defense is not a bar to summary judgment.

 

                    Lack of Mutual Assent

 

The undisputed facts show that Plaintiff and Defendant entered into a valid lease. (Stauffer Decl. ¶ 3.) Defendant has provided no evidence challenging these facts. Defendant admitted the authenticity of the Lease in its request for admission responses. (Compendium, Exh. 20 at pp. 290, 294-295.) It is also undisputed that Defendant remained in possession of the Property during the period between January 1, 2020 and January 31, 2023. (Stauffer Decl. ¶ 8.) Thus, Defendant’s defenses challenging validity fail as a matter of law and the Court concludes that this defense is not a bar to summary judgment.

 

                    Lack of Meeting of the Minds

 

The undisputed facts show that Plaintiff and Defendant entered into a valid lease. (Stauffer Decl. ¶ 3.) Defendant has provided no evidence challenging these facts. Defendant admitted the authenticity of the Lease in its request for admission responses. (Compendium, Exh. 20 at pp. 290, 294-295.) It is also undisputed that Defendant remained in possession of the Property during the period between January 1, 2020 and January 31, 2023. (Stauffer Decl. ¶ 8.) Thus, Defendant’s defenses challenging validity fail as a matter of law and the Court concludes that this defense is not a bar to summary judgment.

 

                    Mistake

 

The undisputed facts show that Plaintiff and Defendant entered into a valid lease. (Stauffer Decl. ¶ 3.) Defendant has provided no evidence challenging these facts. Defendant admitted the authenticity of the Lease in its request for admission responses. (Compendium, Exh. 20 at pp. 290, 294-295.) It is also undisputed that Defendant remained in possession of the Property during the period between January 1, 2020 and January 31, 2023. (Stauffer Decl. ¶ 8.) Thus, Defendant’s defenses challenging validity fail as a matter of law and the Court concludes that this defense is not a bar to summary judgment.

 

                    Material Breach of Contract

 

“Covenants in leases are held to be mutually independent unless the lease expressly or impliedly makes them conditional.” (Goldsmith v. Tub-O-Wash (1962) 199 Cal.App.2d 132, 138.) Thus, “liability under the lease continues as long as the lessee continues in possession.” (Grace v. Croninger (1936) 12 Cal.App.2d 603, 606.)

 

Defendant was in possession of the Property during the period between January 1, 2020 and January 31, 2023. (Stauffer Decl. ¶ 8.) Furthermore, there are no disputed or undisputed facts showing that Defendant breached the lease or otherwise induced nonpayment. Thus, Defendant was required to pay rent during its nonpayment.

 

The Court concludes that this defense is not a bar to summary judgment.

 

                    Material Breach of Representations and Warranties Clause

 

“Covenants in leases are held to be mutually independent unless the lease expressly or impliedly makes them conditional.” (Goldsmith v. Tub-O-Wash (1962) 199 Cal.App.2d 132, 138.) Thus, “liability under the lease continues as long as the lessee continues in possession.” (Grace v. Croninger (1936) 12 Cal.App.2d 603, 606.)

 

Defendant was in possession of the Property during the period between January 1, 2020 and January 31, 2023. (Stauffer Decl. ¶ 8.) Furthermore, there are no disputed or undisputed facts showing that Defendant breached the lease or otherwise induced nonpayment. Thus, Defendant was required to pay rent during its nonpayment.

 

The Court concludes that this defense is not a bar to summary judgment.

 

                    Covenant of Good Faith and Fair Dealing

 

“Covenants in leases are held to be mutually independent unless the lease expressly or impliedly makes them conditional.” (Goldsmith v. Tub-O-Wash (1962) 199 Cal.App.2d 132, 138.) Thus, “liability under the lease continues as long as the lessee continues in possession.” (Grace v. Croninger (1936) 12 Cal.App.2d 603, 606.)

 

Defendant was in possession of the Property during the period between January 1, 2020 and January 31, 2023. (Stauffer Decl. ¶ 8.) Furthermore, there are no disputed or undisputed facts showing that Defendant breached the lease or otherwise induced nonpayment. Thus, Defendant was required to pay rent during its nonpayment.

 

The Court concludes that this defense is not a bar to summary judgment.

 

                    Lack of Consideration

 

The undisputed facts show that Plaintiff and Defendant entered into a valid lease. (Stauffer Decl. ¶ 3.) Defendant has provided no evidence challenging these facts. Defendant admitted the authenticity of the Lease in its request for admission responses. (Compendium, Exh. 20 at pp. 290, 294-295.) It is also undisputed that Defendant remained in possession of the Property during the period between January 1, 2020 and January 31, 2023. (Stauffer Decl. ¶ 8.) Thus, Defendant’s defenses challenging validity fail as a matter of law and the Court concludes that this defense is not a bar to summary judgment.

 

                    Force Majeure

 

The Lease’s force majeure clause provides as follows:

 

12.10. Force Majeure. When this Lease prescribes a time period for a party to take any action (except, in Tenant’s case, for payment of Rent) that party shall not be liable or responsible for … any delays due to … acts of God … , governmental laws, regulations or restrictions, or any act, omission, delay or neglect of that party or its employees or agents, or any other cause whatsoever beyond that party’s reasonable control.

 

(Lease at p. 24.)

 

          Because Defendant’s obligation to pay rent is exempted from the clause, the Court concludes that the clause does not apply and concludes that this defense is not a bar to summary judgment.

 

                    Lack of Damages

 

As discussed above, Plaintiff has proven that Defendant owes Plaintiff $840,738.10 in unpaid rent.

 

The Court therefore grants summary judgment on this defense.

 

                    Acts of Third Parties

 

Defendant contends in its answer that Plaintiff’s damages were caused by acts of third parties. Here, the Lease shows that Plaintiff was the only party obligated to pay rent. (See generally Compendium, Exh. 1 (Lease).) The Court therefore concludes that this defense is not a bar to summary judgment.

 

                    No Repudiation

 

Defendant alleges that its nonpayment was necessitated by Plaintiff’s actions and that it did therefore not repudiate or breach the Lease. As discussed under the Excuse defense, the undisputed facts show that Plaintiff did not take any actions necessitating Defendant’s nonpayment.

 

Defendant alleges that it has merely invoked the force majeure clause. As discussed under the Force Majeure defense, this defense is inapplicable.

 

The Court therefore concludes that this defense is not a bar to summary judgment.

 

                    Unreasonable Mitigation

 

As discussed above under the Failure to Mitigate defense, the duty to mitigate does not apply here. The Court therefore grants summary judgment on this defense.

 

                    Good Faith

 

Under California law, “[c]ontract liability is strict liability,” and “[t]he obligor is therefore liable in damages for breach of contract even if he is without fault and even if circumstances have made the contract more burdensome or less desirable than he had anticipated.” (In re Marriage of Hibbard (2013) 212 Cal.App.4th 1007, 1018 fn. 5.) Thus, good faith is not a defense to breach of contract.

 

The Court therefore concludes that this defense is not a bar to summary judgment.

 

                    Misrepresentation or Concealment

 

The undisputed facts show that Plaintiff and Defendant entered into a valid lease. (Stauffer Decl. ¶ 3.) Defendant has provided no evidence challenging these facts. Defendant admitted the authenticity of the Lease in its request for admission responses. (Compendium, Exh. 20 at pp. 290, 294-295.) It is also undisputed that Defendant remained in possession of the Property during the period between January 1, 2020 and January 31, 2023. (Stauffer Decl. ¶ 8.) Thus, Defendant’s defenses challenging validity fail as a matter of law and the Court concludes that this defense is not a bar to summary judgment.

 

Set-Offs for Breach of Fiduciary Duty and Breach of the Covenant of Good Faith and Fair Dealing

 

Where a judgment debtor has a claim of their own against the judgment creditor, the claims may be set off against each other. (Erlich v. Superior Court of Los Angeles County (1965) 63 Cal.2d 551, 556.)

 

Here, the Court has already granted summary judgment on each of Defendant’s cross-claims against Plaintiff, so there is no potential judgment to set off against Plaintiff’s claims. The Court therefore grants summary judgment on this defense.

 

Furthermore, as a sufficient alternate basis for granting summary judgment, the Court reiterates its above determination that Plaintiff did not owe Plaintiff a fiduciary duty.

 

                    Reservation of Rights

 

A statement in the answer reserving the right to allege further affirmative defenses is not itself an affirmative defense. Affirmative defenses must be specially pleaded in the answer. (Walsh v. West Valley Mission Community College Dist. (1998) 66 Cal.App.4th 1532, 1546.) The Court therefore concludes that this defense is not a bar to summary judgment.

 

Conclusion

 

Having determined that summary judgment for Plaintiff is appropriate on Plaintiff’s cause of action and that none of the affirmative defenses bar summary judgment, the Court grants summary judgment for Plaintiff on its complaint. Because the Court grants summary judgment, Plaintiff’s motion for summary adjudication on the individual issues is moot.