Judge: Lee W. Tsao, Case: 22NWCV00656, Date: 2024-02-14 Tentative Ruling

Case Number: 22NWCV00656    Hearing Date: February 14, 2024    Dept: C

m.g. v. montebello unified school district

CASE NO.:  22NWCV00656

HEARING 2/14/24 @ 9:30 AM

#2

 

Defendant’s Motion for Judgment on the Pleadings is DENIED.

Moving Party to give NOTICE.

 

Defendant Montebello Unified School District (Defendant) moves for judgment on the pleadings on the grounds that Plaintiff M.G.’s (Plaintiff) claims against Defendant are barred by the California Constitution.

Background

Plaintiff alleges he was sexually assaulted by his teacher, Frederick David Johnson while he was a student at Bell Gardens High School during the 1990-1991 school year. Plaintiff filed a Second Amended Complaint pursuant to Assembly Bill 218 (AB 218), for:

1.    Negligence (against Defendant)

2.    Negligence (against DOES 2-25)

3.    Negligent Hiring (against Defendant)

4.    Negligent Hiring (against DOES 2-25)

Defendant filed a Cross-Complaint against Frederick David Johnson for Total Indemnity, Partial Indemnity, and Declaratory Relief. Default against Johnson was entered on November 2, 2023.

Request for Judicial Notice

Plaintiff’s Requests for Judicial Notice Nos. 1-12 are granted under Evidence Code § 452.

Legal Standard

The standard for ruling on a motion for judgment on the pleadings is essentially the same as that applicable to a general demurrer, that is, under the state of the pleadings, together with matters that may be judicially noticed, it appears that a party is entitled to judgment as a matter of law. (Bezirdjian v. O'Reilly (2010) 183 Cal.App.4th 316, 321-322, citing Schabarum v. California Legislature (1998) 60 Cal.App.4th 1205, 1216.) “A demurrer tests the sufficiency of the complaint as a matter of law; as such, it raises only a question of law.” (Osornio v. Weingarten (2004) 124 Cal.App.4th 304, 316.) No matter how unlikely or improbable, the complainant’s allegations must be accepted as true for the purpose of ruling on the demurrer. (Del E. Webb Corp. v. Structural Materials Co. (1981) 123 Cal.App.3d 593, 604.) However, the Court does not need to assume the truth of “contentions, deductions or conclusions of law.” (Aubry v. Tri-City Hospital Dist. (1992) 2 Cal.4th 962, 967.)

Discussion

Defendant moves for judgment on the pleadings on the ground that Plaintiff failed to present a timely government claim as a predicate to filing the lawsuit.  Defendant argues that the Legislature’s retroactive elimination of the government claim requirement for child sexual-abuse cases violates the State’s Constitution. 

In 2019, the Legislature passed AB 218, which amended CCP § 340.1 by authorizing a three-year window within which claims of childhood sexual abuse were revived, regardless of how long ago the abuse occurred. (See CCP § 340.1 (q).) AB 218 also amended Government Code § 905 to retroactively remove the timely claim requirement for claims “made pursuant to Section 340.1 of the Code of Civil Procedure for the recovery of damages suffered as a result of childhood sexual assault.” (See Gov. Code, § 905 (m).) 

Defendant argues that AB 218 violates the State’s Constitution because it creates a private gift of public funds by retroactively stripping the statutory protection under Government Code section 905. The State Constitution “forbids the legislature from making any gift of public money or other thing of value to any person,” thus the Legislature “has no power to create a liability against the state for any such past act of negligence upon the part of its officers.” (Chapman v. State (1894) 104 Cal. 690, 693.) More specifically, the Legislature cannot create a liability against the State “for any past acts of negligence on the part of its officers, agents or employees” where doing so “would, in effect, be the making of a gift.” (Heron v. Riley (1930) 209 Cal. 507, 517.) In this context, the term “gift” includes “‘includes all appropriations of public money for which there is no authority or enforceable claim,’ even if there is a moral or equitable obligation.” (Jordan v. Department of Motor Vehicles (2002) 100 Cal.App.4th 431, 450, quoting Conlin v. Board of Supervisors (1893) 99 Cal. 17, 21-22 (Conlin).) “In determining whether an appropriation of public money is to be considered a gift within the constitutional prohibition, the primary question is whether the funds are to be used for a public or a private purpose. If the money is for a public purpose, the appropriation is not a gift even though private persons are benefited by the expenditure.” (County of Los Angeles v. La Fuente (1942) 20 Cal.2d 870, 876-877.)

Defendant cites a line of cases where the Supreme Court held that the Legislature’s appropriation of public funds to specific persons were unconstitutional. See Bourn v. Hart (1982) 93 Cal. 321, 326-328 (legislative appropriation of $10,000 to specific individual for injuries sustained due to public entity employer's negligence was impermissible gift because employer could not be sued for negligence at the time of injury); Conlin, supra, 99 Cal. 17, 19-24 (legislative appropriation of payment to specific individual for work performed on road improvements, for which the public entity had no liability for under the subject contract, was impermissible gift). 

“The rule is well established [] that if a public purpose is served by the expenditure of public funds, article XIII, section 25, is not violated even though there may be incidental benefits to private persons.” (Board of Supervisors v. Dolan (1975) 45 Cal.App.3d 237, 243 (Dolan) (municipal authorization of low-interest loans to finance residential rehabilitation in depressed residential areas was not a gift even though the loans benefited private parties because redevelopment and prevention of slums is valid public purpose).) The determination of what constitutes a public purpose is primarily a matter for the Legislature, and its discretion will not be disturbed by the courts so long as that determination has a reasonable basis. (County of Alameda v. Carleson (1971) 5 Cal.3d 730, 746 (Carleson).)

Here, AB 218’s legislative history demonstrates that the Legislature enacted the bill to expand access to justice for the victims of childhood sexual assault as a means of preventing similar abuses by future perpetrators. Noting that there “should not be a reasonable expectation that if simply enough time passes, there will be no accountability for these despicable past acts by individuals and entities[,]” the authors of AB 2018 expressly intended that the bill confront the pervasive problem of cover-ups in institutions, from schools to sports leagues, which result in continuing victimization and the sexual assault of additional children. (Plaintiff’s RJN, Ex. 12, p. 2.) AB 2018’s authors expressly intended that the bill serve “as an effective deterrent against individuals and entities who have chosen to protect the perpetrators of sexual assault over the victims.” (Plaintiff’s RJN, Ex. 12, p. 2.)

AB 218’s legislative history demonstrates that the Legislature enacted it to serve the public purpose of deterring future sexual abuse against minor children, including in schools. The Legislature’s determination that deterring future sexual abuse against minor students is a worthy public purpose is properly a matter for the Legislature to decide, and this Court shall not disturb such legislative discretion so long as the Legislature appears to have had a reasonable basis for its conclusions. (See Carleson, supra, 5 Cal.3d at p. 746; see also Dittus v. Cranston (1959) 53 Cal.2d 284, 286 (invalidity of legislation must be clear before it can be declared unconstitutional).)

Here, it is apparent from the legislative history that a reasonable basis exists for the Legislature’s determination that deterring childhood sexual abuse is a public purpose, and that AB 218 was enacted to achieve that purpose. AB 218 does not constitute an unconstitutional provision of a public gift to private individuals because the expenditure of public funds serves the greater public purpose of deterring childhood sexual abuse. (See Dolan, supra, 45 Cal.App.3d at p. 243.) Thus, Defendant’s Motion for Judgment on the Pleadings is denied.

 

Accordingly, Defendant’s Motion for Judgment on the Pleadings is DENIED.