Judge: Lee S. Arian, Case: 22STCV19440, Date: 2025-04-16 Tentative Ruling

Case Number: 22STCV19440    Hearing Date: April 16, 2025    Dept: 27

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT

Background

On July 28, 2022, Plaintiff Katrice Riley filed a complaint for general negligence and motor vehicle negligence against several defendants, including American Honda Motor Co., Inc. (“AHM”), arising from a traffic collision involving Defendant Trenton Williams. At the time of the incident, Mr. Williams was driving from his workplace at Jamba Juice to a friend’s home. AHM had no involvement in the incident. The subject vehicle was leased by Mr. Williams’ mother, Beatrice Byrd-Williams, an AHM employee, for her personal use through an employee lease benefit. AHM now moves for summary judgment on the ground that Plaintiff’s claims are barred under the Graves Amendment.

Legal Standard

“[T]he initial burden is always on the moving party to make a prima facia showing that there are no triable issues of material fact.”¿(Scalf v. D. B. Log Homes, Inc. (2005) 128 Cal.App.4th 1510, 1519.)¿A defendant moving for summary judgment or summary adjudication “has met his or her burden of showing that a cause of action has no merit if the party has shown that one or more elements of the cause of action . . . cannot be established, or that there is a complete defense to the cause of action.”¿(Code Civ. Proc., § 437c, subd. (p)(2).)¿If the moving party fails to carry its burden, the inquiry is over, and the motion must be denied. (See Id.; see also Consumer Cause, Inc. v. SmileCare (2001) 91 Cal.App.4th 454, 468.) 

“Once the defendant … has met that burden, the burden shifts to the plaintiff … to show that a triable issue of one or more material facts exists as to the cause of action or a defense thereto.” (Code Civ. Proc., § 437c, subd. (p)(2).) The plaintiff may not merely rely on 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.”¿(Ibid.)¿“If the plaintiff cannot do so, summary judgment should be granted.”¿(Avivi v. Centro Medico Urgente Medical Center (2008) 159 Cal.App.4th 463, 467.) 

Graves Amendment

The Graves Amendment provides in relevant part:

“An owner of a motor vehicle that rents or leases the            vehicle to a person … shall not be liable under the law of       any State … by reason of being the owner of the vehicle     … for harm to persons or  property that results or arises   out of the use, operation, or possession of the vehicle     during the period of the rental or lease, if—
            (1) the owner (or an affiliate of the owner) is engaged in           the trade or business of renting or leasing motor      v          vehicles; and
            (2) there is no negligence or criminal wrongdoing on the          part of the owner (or an affiliate of the owner).”

(49 U.S.C. § 30106(a).)

The statute further defines “affiliate” as: “a person other than the owner that directly or indirectly controls, is controlled by, or is under common control with the owner.” It explains that “‘control’ means the power to direct the management and policies of a person whether through ownership of voting securities or otherwise.”
(49 U.S.C. § 30106(d).)

Discussion

AHM has met its burden under the Graves Amendment by establishing the statutory requirements for immunity. The 2019 Honda Insight involved in the accident was leased by Beatrice Byrd-Williams, Mr. Williams’ mother, through a personal lease program offered as part of her compensation package with AHM. (SSUF Nos. 5, 6, 8.) AHM held title to the vehicle as the lessor and owner. (SSUF No. 15.) AHM is engaged in the business of leasing motor vehicles. (SSUF Nos. 23–26, 45–49, 69–72.) Finally, there is no evidence of negligence or criminal wrongdoing by AHM. (SSUF Nos. 16, 17, 19, 43, 44, 65–67.) These facts satisfy the requirements of 49 U.S.C. § 30106(a). Accordingly, AHM has met its initial burden under the Graves Amendment.

Plaintiff did not file an opposition. Accordingly, Plaintiff has failed to raise a triable issue of material fact, and the motion is granted.

Parties who intend to submit on this tentative must send an email to the Court at SSCDEPT27@lacourt.org indicating intention to submit on the tentative as directed by the instructions provided on the court’s website at www.lacourt.org.  Please be advised that if you submit on the tentative and elect not to appear at the hearing, the opposing party may nevertheless appear at the hearing and argue the matter.  Unless you receive a submission from all other parties in the matter, you should assume that others might appear at the hearing to argue.  If the Court does not receive emails from the parties indicating submission on this tentative ruling and there are no appearances at the hearing, the Court may, at its discretion, adopt the tentative as the final order or place the motion off calendar.