Judge: Katherine Chilton, Case: 22STLC04567, Date: 2023-04-28 Tentative Ruling

Case Number: 22STLC04567     Hearing Date: April 28, 2023    Dept: 25

PROCEEDINGS:      MOTION FOR SUMMARY JUDGMENT, ALTERNATIVELY SUMMARY ADJUDICATION

 

MOVING PARTY:   Plaintiff Monica Ford

RESP. PARTY:          Defendant Timothy Harris

 

MOTION FOR SUMMARY JUDGMENT,

ALTERNATIVELY, SUMMARY ADJUDICATION

(CCP § 437c)

 

TENTATIVE RULING:

 

The hearing on Plaintiff’s Motion for Summary Judgment, or alternatively, Summary Adjudication is CONTINUED to MAY 31, 2023 at 10:30 a.m. in Department 25 at the SPRING STREET COURTHOUSE.  Plaintiff is ordered to file supplemental papers addressing the issues discussed herein at least 16 court days before the next scheduled hearing.

 

SERVICE: 

 

[X] Proof of Service Timely Filed (CRC 3.1300)             OK

[X] Correct Address (CCP 1013, 1013a)                                     OK

[X] 75/80 Day Lapse (CCP 12c and 1005 (b))                     OK

 

OPPOSITION:          Filed on April 11, 2023.                                    [   ] Late                      [   ] None

REPLY:                     Filed on April 12, 2023.                                    [   ] Late                      [   ] None

 

ANALYSIS:

 

I.                Background

 

On July 11, 2022, Plaintiff Monica Ford (“Plaintiff”) filed an action against Defendant Timothy Harris (“Defendant”) for unlawful retention of security deposit pursuant to Civil Code § 1950.5, breach of residential lease agreement, negligence, and conversion.

 

On November 2, 2022, Defendant filed an Answer to the Complaint.

On February 6, 2023, Plaintiff filed the instant Motion for Summary Judgment or alternatively, Summary Adjudication (“Motion”).  On April 11, 2023, Defendant filed an Opposition to the Motion (“Opposition”) and Plaintiff filed a Reply to the Opposition (“Reply”) on April 12, 2023.

 

II.              Legal Standard

 

A party seeking summary judgment has the burden of producing evidentiary facts sufficient to entitle him/her to judgment as a matter of law.  (Code Civ. Proc. § 437c(c).)  The moving party must make an affirmative showing that he/she is entitled to judgment irrespective of whether or not the opposing party files an opposition.  (Villa v. McFerren (1995) 35 Cal.App.4th 733, 742-743.)  Thus, “the initial burden is always on the moving party to make a prima facie showing that there are no triable issues of material fact.”  (Scalf v. D. B. Log Homes, Inc. (2005) 128 Cal.App.4th 1510, 1519 (citing Aguilar v. Atlantic Richfield Co. (2001) 25 Cal.4th 826, 850.).  When a plaintiff seeks summary judgment, he/she must produce admissible evidence on each element of each cause of action on which judgment is sought.  (Code Civ. Proc., § 437c(p)(1).)  The moving party’s “affidavits must cite evidentiary facts, not legal conclusions or ‘ultimate’ facts” and the courts must construe the evidence in support of the opposing party, resolving any doubts in favor of the opposing party.  (Hayman v. Block (1986) 176 Cal.App.3d 629, 639; Scalf, 128 Cal.App.4th at 1519; Dore v. Arnold Worldwide, Inc. (2006) 39 Cal.4th 384, 389.)

 

The opposing party on a motion for summary judgment is under no evidentiary burden to produce rebuttal evidence until the moving party meets his or her initial movant’s burden.  (Binder v. Aetna Life Insurance Company (1999) 75 Cal.App.4th 832, 840.)  Once the initial movant’s burden is met, then the burden shifts to the opposing party to show, with admissible evidence, that there is a triable issue requiring the weighing procedures of trial.  (Code Civ. Proc. § 437c(p).)  The opposing party may not simply rely on his/her allegations to show a triable issue but must present evidentiary facts that are substantial in nature and rise beyond mere speculation.  (Sangster v. Paetkau (1998) 68 Cal.App.4th 151, 162.)  Summary judgment must be granted “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.)

 

As to any alternative request for summary adjudication of issues, such alternative relief must be clearly set forth in the Notice of Motion and the general burden-shifting rules apply but the issues upon which summary adjudication may be sought are limited by statute.  (Code Civ. Proc., § 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.)

 

 

 

III.            Discussion

 

Plaintiff seeks a court order granting summary judgment in her favor and against Defendant on grounds that there are no triable issues of material fact as to any of the causes of action.  (Mot. p. 2.)  Alternatively, Plaintiff seeks summary adjudication as to each of the four causes of action set forth in the Complaint.  (Ibid.)

 

A.    Unlawful Retention of Security Deposit, Civil Code § 1950.5

 

Civil Code § 1950.5 applies to security deposits for residential property used as a tenant’s dwelling.  (Civ. Code, § 1950.5(a).)

 

“The elements of an action for wrongful retention of a security deposit under Civil Code § 1950.5 are: (1) the plaintiff paid a security deposit; (2) the security deposit was for a residential property; (3) the plaintiff used the property as a dwelling; and (4) the amounts deducted by the defendant were not reasonably necessary. If the plaintiff is seeking punitive damages, then it must also be shown that the defendant made the deductions in bad faith.”  (Peviani v. Arbors at California Oaks Property Owner, LLC (2021) 62 Cal.App.5th 874, 899.)  The bad faith retention of a security deposit may subject the landlord to statutory damages of up to twice the amount of the security deposit in addition to actual damages.  (Civ. Code, § 1950.5(l).)

 

As used in § 1950.5, “security” is defined as “any payment, deposit, or charge, including, but not limited to, any payment, fee, deposit, or charge, except as provided in Section 1950.6, that is imposed at the beginning of the tenancy to be used to reimburse the landlord for costs associated with processing a new tenant or that is imposed as an advance payment of rent, used or to be used for any purpose” including to compensate the landlord for the tenants default in the payment of rent, to repair damages to the premises leased, to clear the premises upon termination of the tenancy and to return the unit to the same level of cleanliness it was in at the inception of the tenancy, or to remedy future defaults by the tenant in any obligation under the rental agreement.  (Civil Code §1950.5(b).)

 

No later than 21 days after the tenant has vacated the premises, the landlord must serve via personal delivery or first-class mail a copy of an itemized statement indicating the basis for and the amount of any security received and the disposition of the security funds and must return any remaining portion of the security to the tenant.  (Civ. Code, § 1950.5(g)(1).)  If a landlord does not provide the tenant with an itemized statement of the portion of the security deposit retained within the required 21-days, then the entire security deposit must be returned to the tenant.  (Granberry v. Islay Investments (1995) 9 Cal.App.4th 738, 744-45.)

 

“Within a reasonable time after notification of either party’s intention to terminate the tenancy, or before the end of the lease term, the landlord shall notify the tenant in writing of the tenant’s option to request an initial inspection and of the tenant’s right to be present at the inspection.”  (Civ. Code § 1950.5(f).)  The inspection shall be conducted “at a reasonable time, but no earlier than two weeks before the termination or end of the lease date” and “shall be to allow the tenant an opportunity to remedy identified deficiencies.”  (Ibid.)

 

“Proof of the existence of and the amount of a security deposit may be established by any credible evidence, including, but not limited to, a canceled check, a receipt, a lease indicating the requirement of a deposit as well as the amount, prior consistent statements or actions of the landlord or tenant, or a statement under penalty of perjury that satisfies the credibility requirements set forth in § 780 of the Evidence Code.”  (Civ. Code, § 1950.5(o).)

 

            In support of her Motion, Plaintiff has presented the following evidence:

 

1.     Exhibit 1 – Residential Lease Agreement between Plaintiff and Defendant.  (Verdun Decl. ¶ 2, Ex. 1.)

2.     Exhibit 2 – Itemized Statement Email.  (Ibid. at ¶ 3, Ex. 2.)

3.     Exhibit 3 – Defendant’s Responses to Plaintiff’s Requests for Admission.  (Ibid. at ¶ 4, Ex. 3.)

4.     Exhibit 4 – Certified Copy of Deposition Transcript of Defendant Harris.  (Ex. 4.)

 

Based on this evidence, Plaintiff states that Defendant rented the property located at 999 North Holliston Ave, Pasadena, CA 91104 (“Property”) as a residential rental property for fifteen (15) years.  (Ex. 4 – Depos. 12:25-13:12)  Plaintiff and Defendant entered into a residential Lease Agreement for the Property on July 8, 2018.  (Ex. 1 – Lease Agreement; Ex. 3 – RFA #1; Ex. 4 – Depos. 5:12-5:22, 5:23-6:1, 7:12-7:25.)  On or around the same date, Plaintiff paid Defendant a security deposit of $3,350 as part of the Lease Agreement for the Property.  (Ex. 1 – Lease Agreement; Ex. 3 – RFA #2; Ex. 4 – Depos. 9:15-9:21.)  Plaintiff gave Defendant notice of her intent to terminate the tenancy on or about April 1, 2022, about six weeks before the move out date.  (Ex. 4 – Depos. 21:12-22:5.)  Defendant has admitted that he did not “obtain advance express consent in the form of a mutual agreement” before serving the itemized statement of the security deposit on Plaintiff by email.  (Ex. 4 – Depos. 31:10-32:6.)  Defendant also admits that he did not notify Plaintiff of her right to an initial inspection two (2) weeks before the move out date and did not provide Plaintiff with “an initial inspection itemized statement” that would give her the opportunity to remedy any issues prior to deduction from the security deposit.  (Ex. 4 – Depos. 21:12-22:5, 77:4-78:3.)  Plaintiff moved out of the Property on May 14, 2022.  (Ex. 4 – Depos. 97:12-97:19, 98:8-99:6.)  Defendant was required to return the security deposit and provide an itemized statement of any deductions with supporting evidence by June 4, 2022.  (Ex. 4. – Depos, 97:12-97:19.)  However, Defendant has admitted that he did not send the itemized list of deductions within 21 days of the date that Plaintiff vacated the Property.  (Ex. 4 – Depos., 98:8-99:6.)  On June 20, 2022, Defendant sent an itemized statement by email, but Plaintiff did not receive this document by personal service or U.S. mail.  (Ex. 4 – Depos. 19:2-20:10, 31:1-31:9.)  Defendant has admitted that he did not return any portion of the security deposit.  (Ex. 4 – Depos. 18:24-19:1.)  Thus, Defendant did not provide Plaintiff notice of her right to an initial inspection, did not conduct an initial inspection, and withheld her entire security deposit.  (Ex. 4 – Depos. 21:12-22:5.)  When Defendant did send Plaintiff an itemized deduction, it was not properly served personally or by mail and did not contain any supporting documents.  (Ex. 4 – Depos. 20:11-20:17.)  Defendant has acknowledged that he does not have sufficient knowledge about his responsibilities regarding security deposits, has never taken any courses or educated himself on how to properly handle security deposits.  (Ex. 4 – Depos. 12:13-12:24, 58:3-59:21.)  Moreover, he did not know that he was legally obligated to provide Plaintiff notice of her right to an initial inspection after her notice to vacate and thus, did not provide such notice.  (Ex. 4 – Depos. 23:15-25:4.)  Defendant also did not know that he had to obtain express consent to serve the itemized statement of deductions by email and thus, did not obtain express consent.  (Ex. 4 – Depos. 32:7-32:17.)

 

The Court finds that Plaintiff has met her burden of demonstrating that Defendant has violated Civil Code § 1950.5 due to failure to notify Plaintiff of her rights to an initial inspection, failure to properly and timely serve Plaintiff with itemized deductions, and as a result, failure to return the full amount of the security deposit to Plaintiff.

 

In response, Defendant has submitted his own declaration.  Defendant does not dispute the following statements presented by Plaintiff.  Defendant rented the Property as a residential property for 15 years, and entered into a residential Lease Agreement with Plaintiff and her husband Tom Ford for this Property on or about July 8, 2018.  (Def. SS ¶¶ 1-3; Harris Decl. ¶¶ 2-3, Ex. A.)  A security deposit in the amount of $3,350 was paid to Defendant.  (Harris Decl. ¶ 4.)  On or around April 1, 2022, Plaintiff gave notice of intent to terminate the tenancy.  (Ibid. at ¶ 5.)  On May 14, 2022, Plaintiff vacated the Property.  (Ibid. at ¶ 9.)  Defendant was obligated to return the deposit and provide an itemized statement of deductions with supporting documentation by June 4, 2022.  (Ibid. at ¶ 10; Harris Decl. ¶ 17.)  Defendant “has a lack of knowledge about his responsibilities when it comes to handling security deposits, admitting he has never taken any training courses, read any books, or taken any steps to educate himself about the proper handling of a security deposit.”  (Def. SS ¶ 16.). He did not know that he had to provide notice of Plaintiff’s right to an initial inspection and thus, did not do so.  (Ibid. at ¶ 17.)

 

However, Defendant disputes the following statements.  The security deposit was paid by both lessees, Monica and Tom Ford.  (Def. SS ¶ 4; Ex. 1 – Lease Agreement; Harris Decl. ¶ 2.)  The Fords vacated the property two days after they stopped paying rent, on May 14, 2022, instead of May 12, 2022.  (Ibid. at ¶ 12.)  Defendant was unaware that the itemized statement had to be served by mail or of Plaintiff’s rights concerning an initial inspection before moving out.  (Def. SS ¶¶ 6-8; Harris Decl. ¶¶ 7, 18-19; Ex. 4 – Depos. 24:1-25:4.)  Defendant did send the itemized deductions, which he did by email on June 6, 2022, together with receipts.  (Def. SS ¶¶ 11-12, 15, 18; Harris Decl. ¶ 7, 17, 21, Ex. E.)  Defendant did not deny Plaintiff an initial inspection and offered to return the security deposit after the lawsuit was initiated.  (Ibid. at ¶¶ 13-14; Harris Decl. ¶ 17, Ex. E.)

 

Defendant adds that “[t]he property was in very good condition when leased to the Fords.”  (Harris Decl. ¶ 5.)  The Fords did not inform Defendant that “they planned to sublease any portion of the property.”  (Ibid. at ¶ 6.)  On July 10, 2018, Defendant’s agent informed Defendant that the Fords would take over the gardener’s obligations and deduct $100 from the month’s rent.  (Ibid. at ¶ 7.)  Without Defendant’s approval, the Fords discharged the gardener and did not take care of the landscaping.  (Ibid. at ¶ 8.)  Defendant had to incur $2,400 in expenses in restoring and cleaning the landscaping.  (Ibid.)  Defendant had to also pay $400 to remove a concrete and stone fire pit that was installed without his permission and $360 for cleaning of the Property.  (Ibid.)  The Fords did not pay rent for two days, in the amount of $216, and accordingly the total costs to Defendant, $3,376, exceeded the amount of the security deposit.  (Ibid.)  Furthermore, Defendant had to pay a $113 citation to the City of Pasadena because the Fords subleased a portion of the Property without informing Defendant.  (Ibid. at ¶¶ 9-10, Ex. C.)  Finally, Defendant has submitted estimates of the costs to refinish his piano that was exposed to direct sunlight and damaged due to the Fords’ conduct, in violation of the Lease Agreement.  (Ibid. at ¶ 11, Ex. D.)

 

Defendant adds personal reasons related to his wife’s immigration application, his business, and health, that impacted his ability to handle the instant matter.  (Harris Decl. ¶¶ 13-16.)  As a result of these reasons, Defendant was overwhelmed and could not deal with the Plaintiff’s decision to vacate unexpectedly.  (Ibid. at ¶ 16.)  He has not acted in bad faith or with malice toward the Fords and has been accommodating to them throughout the lease.  (Ibid.at ¶¶ 18-19.)  Defendant also attached the full deposition, arguing that Plaintiff’s exhibit containing portions of the deposition is not complete.  (Ibid. at ¶ 21, Ex. F.)

 

In her Reply, Plaintiff argues that “Defendant did not raise a single issue of material fact – and in fact admits the violations.”  (Reply p. 1.)  Defendant asserts that he was ignorant of the law, however, § 1950.5 does not required awareness of the statutory requirements.  (Ibid.)  Moreover, acting in bad faith is also not required to establish a violation of § 1950.5, as a finding of bad faith pertains to the issue of damages, not liability.  (Ibid. at p. 4.)

 

Plaintiff also objects to portions of Defendant’s declaration that discuss Plaintiff’s alleged conduct throughout the lease that caused Defendant to incur expenses on the ground of relevance.  (4-12-23 Response ¶¶ 23-26.)  Plaintiff states that “this evidence may be useful for mitigation at trial, or in a cross-complaint, it is not relevant for the matters raised in this hearing.”  (Ibid.)  Moreover, Plaintiff objects to Defendant’s discussion of the circumstances around his wife’s immigration status, business, and health, which are not relevant to matters raised at this hearing or a valid defense to liability under §1950.5.  (Ibid. at ¶¶ 27-29.)

 

Finally, Plaintiff objects to the relevance of Defendant’s statement regarding his offer to return the security deposit after the lawsuit was filed, arguing that “efforts to resolve the dispute after the lawsuit is filed cannot negate liability” and are not relevant.  (Ibid. at p. 5.)

 

The Court OVERRULES Plaintiff’s Objections #1-14 as they may be relevant to the determination of whether Defendant acted in bad faith.

 

The Court finds that Plaintiff has sustained her burden of showing that there is no material dispute of fact regarding Defendant’s violation of Civil Code § 1950.5 and unlawful retention of the security deposit.  However, the Court finds that there is a triable issue of material fact as to the determination of damages stemming from the violation of § 1950.5.

 

Civil Code § 1950.5(l), “[T]he bad faith claim or retention by a landlord … of the security or any portion thereof in violation of this section, or the bad faith demand of replacement security in violation of subdivision (j), may subject the landlord or the landlord’s successors in interest to statutory damages of up to twice the amount of the security, in addition to actual damages. The court may award damages for bad faith whenever the facts warrant that award, regardless of whether the injured party has specifically requested relief. In an action under this section, the landlord or the landlord’s successors in interest shall have the burden of proof as to the reasonableness of the amounts claimed or the authority pursuant to this section to demand additional security deposits.”  [Emphasis added.]

 

Here, Plaintiff seeks statutory damages “[t]wo times the amount of the entire deposit.”  (Compl. p. 16.)  However, Plaintiff’s evidence is not sufficient to show Defendant’s failure to return the security deposit was conducted in bad faith.

 

For this reason, Plaintiff’s Motion for Summary Adjudication as to the first cause of action is DENIED.

 

B.    Breach of Residential Lease Agreement, Negligence, and Conversion Causes of Action

 

For the following causes of action – breach of residential lease agreement, negligence, and conversion, Plaintiff incorporates facts set forth in the first cause of action for violation of Civil Code § 1950.5.

 

A motion for summary judgment “shall include a separate statement setting forth plainly and concisely all material facts that the moving party contends are undisputed.”  (Code of Civ. Proc. § 437c(b)(1).)  Moreover, California Rules of Court, rule 3.1350, sets forth the following requirements for the Separate Statement:

 

(1) The Separate Statement of Undisputed Material Facts in support of a motion must separately identify:

(A) Each cause of action, claim for damages, issue of duty, or affirmative defense that is the subject of the motion; and

(B) Each supporting material fact claimed to be without dispute with respect to the cause of action, claim for damages, issue of duty, or affirmative defense that is the subject of the motion.

(2) The separate statement should include only material facts and not any facts that are not pertinent to the disposition of the motion.

Here, Court finds that Plaintiff’s Separate Statement is defective and does not “plainly and concisely” present the facts that are relevant to the disposition of the second through fourth causes of action.  The Court cannot discern which of the facts presented for the first cause of action are dispositive to the elements for breach of lease agreement, negligence, and conversion.  The Court also notes that Plaintiff has included a fifth cause of action for violation of the Business and Professions Code §17200.  (Sep. St. p. 6.)  The fifth cause of action is not included in Plaintiff’s Complaint or anywhere in the instant Motion.

 

Accordingly, the hearing on the instant Motion is continued.  Plaintiff is ordered to file a supplemental Separate Statement that presents facts that are material to the elements for causes of action for breach of lease agreement, negligence, and conversion.

 

IV.           Conclusion & Order

 

For the foregoing reasons,

 

The hearing on Plaintiff’s Motion for Summary Judgment, or alternatively, Summary Adjudication is CONTINUED to MY 31, 2023 at 10:30 a.m. in Department 25 at the SPRING STREET COURTHOUSE.  Plaintiff is ordered to file supplemental papers addressing the issues discussed herein at least 16 court days before the next scheduled hearing.

 

Moving party is ordered to give notice.