Judge: Laura A. Seigle, Case: 20STCV20137, Date: 2023-03-03 Tentative Ruling
Case Number: 20STCV20137 Hearing Date: March 3, 2023 Dept: 15
[TENTATIVE] ORDER RE MOTION FOR SUMMARY JUDGMENT
Plaintiffs
Linnea Freeman, Dennea Freeman, and Katti Freeman allege Dennis Freeman was
injured by products from Kaiser Gypsum Company, Inc. and Hanson Permanent
Cement, Inc. (“Defendants”). Defendants filed this motion for summary adjudication
of the third cause of action contending Plaintiffs have no evidence of any
misrepresentation or fraudulent concealment to support the third cause of
action.
A defendant seeking
summary judgment must “conclusively negate[] a necessary element of the
plaintiff’s case, or . . . demonstrate[] that under no hypothesis is there a
material issue of fact that requires the process of trial.” (Guz v. Bechtel Nat. Inc. (2000) 24
Cal.4th 317, 334.) To show that a
plaintiff cannot establish an element of a cause of action, a defendant must
make the initial showing “that the plaintiff does not possess, and cannot
reasonably obtain, needed evidence.” (Aguilar
v. Atlantic Richfield Co. (2001) 25 Cal.4th 826, 854.) “The defendant may, but need not, present
evidence that conclusively negates an element of the plaintiff’s cause of
action. The defendant may also present
evidence that the plaintiff does not possess, and cannot reasonably obtain,
needed evidence – as through admissions by the plaintiff following extensive
discovery to the effect that he has discovered nothing.” (Id. at p. 855.) A plaintiff’s deposition testimony that the
plaintiff has no knowledge of any exposure to the defendant’s products may be
sufficient to shift the burden to the plaintiff to demonstrate the existence of
triable issues of fact. (McGonnell v.
Kaiser Gypsum Co., Inc. (2002) 98 Cal.App.4th 1098, 1103-1104.) The plaintiff’s deposition testimony that he
did not recall ever working with a product manufactured by the defendant may
not be sufficient to shift the burden if the plaintiff is able to prove his
case by another means. (Weber v. John
Crane, Inc. (2006) 143 Cal.App.4th 1433, 1439.) “ ‘If plaintiffs respond to comprehensive
interrogatories seeking all known facts with boilerplate answers that restate
their allegations, or simply provide laundry lists of people and/or documents,
the burden of production will almost certainly be shifted to them once
defendants move for summary judgment and properly present plaintiff’s factually
devoid discovery responses.’” (Id.
at p. 1440.)
The third cause of action
is for “False Representation Under Restatement of Torts Section 402-B.” (FAC at p. 14.) Section 402-B establishes “liability for
injuries caused by justifiable reliance on false advertising.” (Westlye v. Look Sports, Inc. (1993)
17 Cal.App.4th 1715, 1750.) Under this
section “ ‘[o]ne engaged in the business of selling chattels who, by advertising,
labels, or otherwise, makes to the public a misrepresentation of a material
fact concerning the character or quality of a chattel sold by him is subject to
liability for physical harm to a consumer of the chattel caused by justifiable
reliance upon the misrepresentation, even though [¶] (a) it is not made
fraudulently or negligently, and [¶] (b) the consumer has not bought the
chattel from or entered into any contractual relation with the seller.’ [Citation.]”
(Id. at pp. 1750-1751.)
“The rule ‘is one of strict liability for physical harm to the consumer,
resulting from a misrepresentation of the character or quality of the chattel
sold, even though the misrepresentation is an innocent one, and not made
fraudulently or negligently.’
[Citation.]” (Hauter v.
Zogarts (1975) 14 Cal.3d 104, 114.)
Defendants argue there is
no evidence Dennis Freeman heard or saw a false statement from Defendants upon
which he relied. (Motion at pp. 8-9.) Under section 402-B, the “‘reliance need not
necessarily be that of the consumer who is injured. It may be that of the ultimate purchaser of
the chattel . . . who because of such reliance passes it on to the consumer who
is in fact injured, but is ignorant of the misrepresentation.’ [Citation.]”
(Westlye, supra, 17 Cal.App.4th at p. 1751.)
The complaint is
extremely vague about how Dennis Freeman was exposed to asbestos. Plaintiffs state in their opposition that
Dennis Freeman was exposed to Defendants’ products when he was working on
construction jobs. (Opposition at p. 2.) Therefore, to the extent his employer
provided the products for him to use when he was employed on construction jobs,
this is a situation where the ultimate purchaser of the product is not the
plaintiff. Because the third cause of action
does not require evidence that Dennis Freemen, as opposed to the ultimate
purchaser of the masks, knew about or relied on any representation by Defendants,
Defendants’ argument that Dennis Freeman did not rely on any statement of
Defendants fails.
Defendants also argue
that previously they were debtors in a bankruptcy proceeding, and the
bankruptcy stay was lifted only “for the purpose of pursuing claims that are
covered by . . . the Debtor’s available insurance.” (Motion at p. 11; Robles Decl., Ex. L at p. 3.) Defendants argue that because fraud claims
are not covered by insurance, the third cause of action remains subject to the
bankruptcy stay. (Motion at pp. 12-13.) However, a cause of action under Restatement
of Torts Section 402-B does not require willfulness. A defendant can be subject to the cause of
action for a misrepresentation “even though . . . it is not made fraudulently
or negligently.” (Westlye, supra,
17 Cal.App.4th at p. 1750; see also Hauter, supra, 14 Cal.3d at p. 114
[rule applies “even though the misrepresentation is an innocent one, and not
made fraudulently or negligently”].)
Therefore, Defendants did not show that the third cause of action is
covered by the bankruptcy stay.
The motion for summary
adjudication of the third cause of action is DENIED.
The moving party is to
give notice.