Judge: Joseph Lipner, Case: 23STCV11836, Date: 2023-11-16 Tentative Ruling

Case Number: 23STCV11836    Hearing Date: April 4, 2024    Dept: 72

SUPERIOR COURT OF CALIFORNIA

COUNTY OF LOS ANGELES

 

DEPARTMENT 72

 

TENTATIVE RULING

 

ROSENDIN ELECTRIC, INC.,

 

                                  Plaintiff,

 

         v.

 

 

CORE/RELATED GRAND AVE. OWNER, LLC., et al.,

 

                                  Defendants.

 

 Case No:  23STCV11836

 

 

 

 

 

 Hearing Date:  April 4, 2024

 Calendar Number:  5

 

 

 

Plaintiff and Cross-Defendant Rosendin Electric, Inc. (“Plaintiff”) and Cross-Defendant Rosendin Holdings, Inc. (“Holdings”) (collectively, “Cross-Defendants”) demur to the second, fourth, sixth, seventh, eighth, ninth, and tenth causes of action in the First Amended Cross-Complaint (“FACC”) filed by Defendant and Cross-Plaintiff Core/Related Grand Ave Owner, LLC (“Core”).

 

The Court SUSTAINS the demurrer WITHOUT LEAVE TO AMEND as to the fourth, sixth, eighth and tenth causes of action.

 

The Court SUSTAINS the demurrer WITH LEAVE TO AMEND as to the second, seventh and ninth causes of action.  Cross-Defendants shall have 20 days to amend the FACC. 

 

Background

 

This is a contract dispute concerning electrical work performed by Plaintiff on a construction project owned by Core. Related is the parent company of Core.

 

Plaintiff and Core entered into a contract (the “Trade Contract”) under which Plaintiff would perform electrical and fire alarm work for Core’s construction project at 100 South Grand Avenue, Los Angeles, California 90012 (the “Property”). Plaintiff alleges that Core had the responsibility for project design and for the coordination of the various trades. Core alleges that Plaintiff had responsibility for designing the electrical and fire alarm systems.

 

Plaintiff alleges in its complaint that Core oversaw major changes to the design. Core’s general contractor allegedly failed to consistently manage the construction schedule and provide consistent supervision over the course of the project. These factors significantly increased the costs that fell on Plaintiffs as a result of the work. However, Core refused to issue change orders and make payments for the costs resulting from the scheduling problems and its alterations.

 

Core alleges that Cross-Defendants were aware of the design challenges that they would face and nevertheless performed late and defective work on the project.

 

Plaintiff filed a mechanic’s lien against Core, Related, and several affiliated entities which hold real property interests in the Property.

 

Plaintiff filed this action against Core, the Related Companies, L.P. (“Related”), and United States Fire Insurance (“US Fire”) (collectively, “Defendants”) on May 25, 2023.

 

Core filed a Cross-Complaint against Plaintiff and Holdings, Plaintiff’s parent company, on September 28, 2023, raising claims for (1) breach of contract; (2) breach of fiduciary duty; (3) quasi-contract-unjust enrichment/restitution; (4) promissory fraud; (5) negligent misrepresentation; (6) negligence; (7) constructive fraud; and (8) declaratory relief.

 

On December 28, 2023, the Court sustained, with leave to amend, Cross-Defendants’ demurrer to the claims for breach of fiduciary duty, promissory fraud, negligent misrepresentation, negligence, and constructive fraud.

 

Core filed the FACC, the operative cross-complaint, against Cross-Defendants on February 5, 2024. The FACC raises claims for (1) breach of consultant contract; (2) contractual indemnification; (3) breach of trade contract; (4) breach of fiduciary duty; (5) quasi-contract-unjust enrichment/restitution; (6) promissory fraud; (7) concealment; (8) negligent misrepresentation; (9) negligence; (10) constructive fraud; and (11) declaratory relief.

 

Cross-Defendants demurred to the second, fourth, sixth, seventh, eighth, ninth, and tenth claims on March 27, 2024. Core filed an opposition and Cross-Defendants filed a reply.

 

Judicial Notice

 

The Court denies as moot Core’s request for judicial notice of the Court’s previous order in this case and of the transcript of the hearing over Plaintiff’s previous demurrer to the Cross-Complaint, because those materials are already in the record.

 

The Court grants Core’s sixth request for judicial notice as public records of a court.

 

The Court denies Core’s remaining requests for judicial notice of various law treatises and law journal articles. Core argues that these materials constitute common knowledge or indisputable facts. The materials in question are articles discussing the state of the law. Thus, while the Court can take judicial notice of their existence, it cannot use judicial notice as a means to backend their contentions of law into the record where they would not otherwise be appropriate. Core may cite to these articles in its papers where it is appropriate to do so, but this is not a viable means to, for example, bring in unpublished cases.

 

Legal Standard

 

Demurrer

 

As a general matter, in a demurrer proceeding, the defects must be apparent on the face of the pleading or via proper judicial notice. (Donabedian v. Mercury Ins. Co. (2004) 116 Cal.App.4th 968, 994.) “A demurrer tests the pleading alone, and not the evidence or facts alleged.” (E-Fab, Inc. v. Accountants, Inc. Servs. (2007) 153 Cal.App.4th 1308, 1315.) The court assumes the truth of the complaint’s properly pleaded or implied factual allegations. (Ibid.) The only issue a demurrer is concerned with is whether the complaint, as it stands, states a cause of action. (Hahn v. Mirda (2007) 147 Cal.App.4th 740, 747.)

 

Where a demurrer is sustained, leave to amend must be allowed where there is a reasonable possibility of successful amendment. (Goodman v. Kennedy (1976) 18 Cal.3d 335, 348.) The burden is on the plaintiff to show the court that a pleading can be amended successfully. (Ibid.; Lewis v. YouTube, LLC (2015) 244 Cal.App.4th 118, 226.) However, “[i]f there is any reasonable possibility that the plaintiff can state a good cause of action, it is error to sustain a demurrer without leave to amend.” (Youngman v. Nevada Irrigation Dist. (1969) 70 Cal.2d 240, 245). 

 

Discussion

 

Contractual Indemnity – Second Cause of Action

 

The elements for equitable indemnity are (1) a showing of fault on the part of the indemnitor and (2) resulting damages to the indemnitee for which the indemnitor is contractually or equitably responsible. (Gouvis Engineering v. Superior Court (1995) 37 Cal.App.4th 642, 646.) “To state a claim for equitable indemnity, a defendant must allege the same harm for which he may be held liable is properly attributable—at least in part—to the cross-defendant.” (Platt v. Coldwell Banker Residential Real Estate Services (1990) 217 Cal.App.3d 1439, 1445, fn.7.)

 

“An indemnitee seeking to recover on an agreement for indemnification must allege the parties’ contractual relationship, the indemnitee’s performance of that portion of the contract which gives rise to the indemnification claim, the facts showing a loss within the meaning of the parties’ indemnification agreement, and the amount of damages sustained.” (Four Star Electric, Inc. v. F & H Construction (1992) 7 Cal.App.4th 1375, 1380.)

 

Cross-Defendants argue that Core has not alleged the existence of a third-party claim triggering liability. Cross Defendants are correct, as the definition of “Claims” in the contract is a third-party claim.

 

Section 7.1 of the Preconstruction Consultant Contract executed by the parties states, in relevant part, that: “To the fullest extent permitted by law, [Plaintiff] shall indemnify, protect, defend, and hold harmless the Client and its employees, Client's contract agents assigned to the Project, all parties listed on Exhibit "D", and any and all of their partners, members, successors and assigns (collectively, “Indemnitees”) from and against any claims, damages, losses, liabilities, costs, actions, causes of action, suits, penalties, fines and expenses, including but not limited to reasonable attorneys’ fees (“Claims”), arising out of, resulting from and occurring in connection with the performance of [Plaintiff’s] Services under this Contract …. [Plaintiff’s] duty to defend Client shall be triggered by the presentation of any Claim to [Plaintiff] which results from, arises out of or occurs in connection with Consultant's or any of its subconsultant's work or services.” (Complaint, Exh. A at p. 6-7, ¶ 7.1, emphasis added.)

 

Section 7.2 provides that: “In addition to the indemnity provided in Section 7.1 above intended to cover third party general liability claims under [Plaintiff’s] commercial general liability policy, with respect to claims and liabilities relating to [Plaintiff’s] professional errors and omissions, [Plaintiff] agrees, to the fullest extent permitted by law, to indemnify and hold the Indemnitees harmless against Claims that are caused by the negligent acts, errors or omissions of Consultant in the performance of professional services under this Contract[.]” (Complaint, Exh. A at p. 7, ¶ 7.2.)

 

Core argues that the definition of “Claims” in Section 7.1, which broadly includes any damages and losses suffered by Core, does not limit itself to third-party claims, and rather covers any losses that Core suffers. Section 7.2 belies this argument, however, clarifying that Section 7.1 is “intended to cover third party general liability claims under [Plaintiff’s] commercial general liability policy[.]”  (Complaint, Exh. A at p. 7, ¶ 7.2.) Thus, although the language of Section 7.1 implicitly gives rise to a broader reading of the term “Claims,” the express language of Section 7.2 limits the scope of Section 7.2, and therefore the scope of the term “Claims,” to third-party liability.

 

Thus, Core must plead the existence of a third-party claim. It has not done so.

 

The Court sustains the demurrer to this claim with leave to amend.

 

Breach of Fiduciary Duty – Fourth Cause of Action

 

“The elements of a cause of action for breach of fiduciary duty are the existence of a fiduciary relationship, breach of fiduciary duty, and damages.” (Oasis West Realty, LLC v. Goldman (2011) 51 Cal.4th 811, 820.)

 

Core argues Plaintiff owed it fiduciary duties because Plaintiff was a designer-builder under the Trade Contract. The primary case that Core cites in support of its proposition that a designer-builder is a fiduciary is Edward Barron Estate Co. v. Woodruff Co. (1912) 163 Cal. 561. There, the California Supreme Court held that the defendant, who acted as the architect, engineer, superintendent, and general contractor for the plaintiff, owed the plaintiff fiduciary duties. (Id. at pp. 566-567, 575-576.) A court of appeal later reaffirmed Edward Barron, stating that “[a]n architect owes to his client a fiduciary duty of loyalty and good faith.” (Palmer v. Brown (1954) 127 Cal.App.2d 44, 59.)

 

The Court previously sustained the demurrer to this claim because this case contains a crucial distinction: Plaintiff did not act as an architect, nor did it act as a general contractor or superintendent of construction. At most, Core alleges that Plaintiff had responsibility for designing the electrical systems. Plaintiff’s role is simply nowhere near the all-encompassing role contemplated in Edward Barron, nor is it the role of architect as contemplated in Palmer. McCauley v. Dennis (1963) 220 Cal.App.2d 627, also cited by Core, explicitly stated that it “[does] not establish that a fiduciary relationship exists between a contractor and a person who engages his services simply on the basis of the engagement nor is it so on the basis of the contract.” (Id. at p. 636.) The Court stated that it saw no reason to create new law by holding that any construction contractor who plays a design role becomes a fiduciary of the project owner.

 

Core largely repeats its arguments against the previous demurrer, adding only citations to unpublished federal cases and secondary sources – and not binding authority. Nor has Core supplied additional facts that would allow the Court to find that Plaintiff took on duties comparable to the defendants in Edward Barron or Palmer.

 

The Court has already permitted amendment to this claim once, and Core has failed to allege facts that would remedy its defects. The Court therefore sustains the demurrer to this claim without leave to amend.

 

Promissory Fraud – Sixth Cause of Action

 

“Promissory fraud is a subspecies of the action for fraud and deceit. A promise to do something necessarily implies the intention to perform; hence, where a promise is made without such intention, there is an implied misrepresentation of fact that may be actionable fraud. The elements of promissory fraud (i.e., of fraud or deceit based on a promise made without any intention of performing it) are: (1) a promise made regarding a material fact without any intention of performing it; (2) the existence of the intent not to perform at the time the promise was made; (3) intent to deceive or induce the promisee to enter into a transaction; (4) reasonable reliance by the promisee; (5) nonperformance by the party making the promise; and (6) resulting damage to the promise.” (Behnke v. State Farm General Insurance Co. (2011) 196 Cal.App.4th 1443, 1453 [citation and quotation marks omitted].) The facts constituting the alleged fraud must be alleged factually and specifically as to every element of fraud, as the policy of “liberal construction” of the pleadings will not ordinarily be invoked. (Lazar v. Superior Court (1996) 12 Cal.4th 631, 645.) To properly allege fraud against a corporation, the plaintiffs must plead the names of the persons allegedly making the false representations, their authority to speak, to whom they spoke, what they said or wrote, and when it was said or written. (Tarmann v. State Farm Mut. Auto. Ins. Co. (1991) 2 Cal.App.4th 153, 157.)

 

Plaintiff contends that Core cannot show fraud because it has failed to plead facts showing Plaintiff’s intent not to perform and because Core has alleged performance by Plaintiff in the Cross-Complaint.

 

“[S]omething more than nonperformance is required to prove the defendant's intent not to perform his promise.” (Magpali v. Farmers Group, Inc. (1996) 48 Cal.App.4th 471, 481.) “[F]raudulent intent must often be established by circumstantial evidence …. for example … such circumstances as defendant's insolvency, his hasty repudiation of the promise, his failure even to attempt performance, or his continued assurances after it was clear he would not perform.” (Tenzer v. Superscope, Inc. (1985) 39 Cal.3d 18, 30.)

 

Core argues that it is sufficient to plead in conclusory fashion the falsity of the promise, citing to Beckwith v. Dahl (2012) 205 Cal.App.4th 1039, 1062 [“[B]y sufficiently pleading [the defendant’s] promise was false at the time she made it, [the plaintiff] also sufficiently pled the element of scienter.”]. However, a full reading of the Beckwith analysis of the plaintiff’s promissory fraud claim indicates that it was the element of misrepresentation, and not knowledge of falsity, that the parties intensely litigated. (Id. at pp. 1060-1062.) In fact, the Beckwith court reiterated that “[e]ach element [of fraud] must be alleged with particularity.” (Id. at p. 1060.)

 

          Core has not provided additional facts showing Plaintiff’s intent not to perform at the time of the promise.

 

The Court has already permitted amendment to this claim once, and Core has failed to allege facts that would remedy its defects. The Court therefore sustains the demurrer to this claim without leave to amend.

 

Concealment – Seventh Cause of Action

 

“The elements of fraud are (a) a misrepresentation (false representation, concealment, or nondisclosure); (b) scienter or knowledge of its falsity; (c) intent to induce reliance; (d) justifiable reliance; and (e) resulting damage.” (Hinesley v. Oakshade Town Ctr. (2005) 135 Cal.App.4th 289, 294.)

 

“[T]he elements of an action for fraud and deceit based on concealment are: (1) the defendant must have concealed or suppressed a material fact, (2) the defendant must have been under a duty to disclose the fact to the plaintiff, (3) the defendant must have intentionally concealed or suppressed the fact with the intent to defraud the plaintiff, (4) the plaintiff must have been unaware of the fact and would not have acted as he did if he had known of the concealed or suppressed fact, and (5) as a result of the concealment or suppression of the fact, the plaintiff must have sustained damage.” (Lovejoy v. AT&T Corp. (2004) 119 Cal.App.4th 151, 157–158.)

 

The facts constituting the alleged fraud must be alleged factually and specifically as to every element of fraud, as the policy of “liberal construction” of the pleadings will not ordinarily be invoked. (Lazar v. Superior Court (1996) 12 Cal.4th 631, 645.) To properly allege fraud against a corporation, the plaintiffs must plead the names of the persons allegedly making the false representations, their authority to speak, to whom they spoke, what they said or wrote, and when it was said or written. (Tarmann v. State Farm Mut. Auto. Ins. Co. (1991) 2 Cal.App.4th 153, 157.)

 

The only basis that Core pleads to establish that Plaintiff had a duty of disclosure was that Plaintiff was a fiduciary to Core. As discussed under the breach of fiduciary duty claim, Core has not adequately alleged such a fiduciary relationship. Core has therefore failed to plead the second element.

 

The Court sustains the demurrer to this claim with leave to amend.

 

Negligent Misrepresentation – Eighth Cause of Action

 

The elements of a cause of action for negligent misrepresentation include “[m]isrepresentation of a past or existing material fact, without reasonable ground for believing it to be true, and with intent to induce another’s reliance on the fact misrepresented; ignorance of the truth and justifiable reliance on the misrepresentation by the party to whom it was directed; and resulting damage.” (Hydro-Mill Co., Inc. v. Hayward, Tilton & Rolapp Ins. Associates, Inc. (2004) 115 Cal.App.4th 1145, 1154, quotation marks omitted.) The facts constituting the alleged fraud must be alleged factually and specifically as to every element of fraud, as the policy of “liberal construction” of the pleadings will not ordinarily be invoked. (Lazar v. Superior Court (1996) 12 Cal.4th 631, 645.) To properly allege fraud against a corporation, the plaintiff must plead the names of the persons allegedly making the false representations, their authority to speak, to whom they spoke, what they said or wrote, and when it was said or written. (Tarmann v. State Farm Mut. Auto. Ins. Co. (1991) 2 Cal.App.4th 153, 157.)

 

“California courts have recognized a cause of action for negligent misrepresentation, i.e., a duty to communicate accurate information, in two circumstances. The first situation arises where providing false information poses a risk of and results in physical harm to person or property. The second situation arises where information is conveyed in a commercial setting for a business purpose.” (Friedman v. Merck & Co. (2003) 107 Cal.App.4th 454, 477.)

 

The Court previously sustained a demurrer where core alleged that Plaintiff’s misrepresentations include: “[Plaintiff] had the necessary skill, experience and ability to act as design-builder”; [Plaintiff] was “fully familiar with and would and could comply with the applicable building and safety codes”; “all design and construction work was being performed and would and could be performed to the satisfaction of [Core] and applicable governmental officials and in a workmanlike manner without defects or delays”; “that the electrical and fire alarm systems work for the Project would be designed and built in a timely manner that would and could be completed in accordance with the Project schedule; and that [Plaintiff] was “financially responsible and capable to fully and timely pay for all labor, work, and materials furnished by their subcontractors and suppliers for the Project and account to Related for the costs incurred at the Project.” (Cross-Complaint ¶ 61.)

 

On amendment, Core once again alleges only very general representations regarding Plaintiff’s ability to complete the work – such as that Plaintiff was highly qualified, had a good working relationship with local regulators, and would be able to work well with the architect Core had hired, who allegedly has a difficult personality.

 

These allegations fail to meet the heightened pleading standard for fraud because they only plead general statements of qualification and not specific representations of fact.

 

The Court has already permitted amendment to this claim once, and Core has failed to allege facts that would remedy its defects. The Court therefore sustains the demurrer to this claim without leave to amend.

 

Negligence – Ninth Cause of Action

                      

In order to state a claim for negligence, Plaintiff must allege the elements of (1) “the existence of a legal duty of care,” (2) “breach of that duty,” and (3) “proximate cause resulting in an injury.” (McIntyre v. Colonies-Pacific, LLC (2014) 228 Cal.App.4th 664, 671.)

 

“[C]ourts will generally enforce the breach of a contractual promise through contract law, except when the actions that constitute the breach violate a social policy that merits the imposition of tort remedies.” (Erlich v. Menezes (1999) 21 Cal.4th 543, 552.) “Generally, outside the insurance context, “a tortious breach of contract ... may be found when (1) the breach is accompanied by a traditional common law tort, such as fraud or conversion; (2) the means used to breach the contract are tortious, involving deceit or undue coercion or; (3) one party intentionally breaches the contract intending or knowing that such a breach will cause severe, unmitigable harm in the form of mental anguish, personal hardship, or substantial consequential damages.” (Id. at pp. 553-554, quoting Freeman & Mills, Inc. v. Belcher Oil Co. (1995) 11 Cal.4th 85, 105.) “Focusing on intentional conduct gives substance to the proposition that a breach of contract is tortious only when some independent duty arising from tort law is violated. If every negligent breach of a contract gives rise to tort damages the limitation would be meaningless, as would the statutory distinction between tort and contract remedies. (Id. at p. 554 [emphasis added] [citation omitted].)

 

Here, there was contractual privity between Plaintiff and Core. Core has not identified a violation of social policy meriting the imposition of tort remedies, nor has Core adequately pled fraud, conversion, deceit, coercion, intentional breach, or any other intentional tort that would give rise to parallel contractual liability. Furthermore, Erlich appears to explicitly limit parallel tort liability to intentional torts, excluding negligence as a matter of law.

 

“Speaking very generally, tort law provides a remedy for construction defects that cause property damage or personal injury.” (Aas v. Superior Court (2000) 24 Cal.4th 627, 635.) “But the difference between price paid and value received, and deviations from standards of quality that have not resulted in property damage or personal injury, are primarily the domain of contract and warranty law or the law of fraud, rather than of negligence.” (Id. at p. 636.)

 

Here, Core alleges that “there have been significant design and construction defects, incomplete work, property damage and other losses” without any further clarification. The mere allegation of the words “property damage” without stating what damage actually occurred is conclusory. Core need not plead evidentiary facts showing property damage, but it must still plead the ultimate fact of the damage that occurred.

 

Further, Core pleads the exact same amount in damages for negligence that it seeks in its breach of contract claims, creating an appearance that Core is improperly seeking economic damages.

 

The Court therefore sustains the demurer with leave to amend.

 

Constructive Fraud – Tenth Cause of Action

 

“Constructive fraud is a unique species of fraud applicable only to a fiduciary or confidential relationship.” (Prakashpalan v. Engstrom, Lipscomb & Lack (2014) 223 Cal.App.4th 1105, 1131 [citation and quotation marks omitted].) “Constructive fraud arises on a breach of duty by one in a confidential or fiduciary relationship to another which induces justifiable reliance by the latter to his prejudice.” (Ibid. [citation and quotation marks omitted].) “Constructive fraud exists in cases in which conduct, although not actually fraudulent, ought to be so treated—that is, in which such conduct is a constructive or quasi fraud, having all the actual consequences and all the legal effects of actual fraud.” (Ibid. [citation and quotation marks omitted].)

 

The elements of a constructive fraud cause of action are (1) a fiduciary duty or confidential relationship, (2) nondisclosure (breach of fiduciary duty); (3) intent to deceive, and (4) reliance resulting in injury. (Younan v. Equifax Inc. (1980) 111 Cal.App.3d 498, 516, fn. 14.)

 

Core still relies on its allegations that the “design/build” relationship between the parties establishes a fiduciary duty. As discussed under the breach of fiduciary duty claim, Core has not adequately pled the existence of a fiduciary relationship.

 

The Court has already permitted amendment to this claim once, and Core has failed to allege facts that would remedy its defects. The Court therefore sustains the demurrer to this claim without leave to amend.