Judge: Lee W. Tsao, Case: 23NWCV02921, Date: 2024-04-25 Tentative Ruling
Case Number: 23NWCV02921 Hearing Date: April 25, 2024 Dept: C
RHA v. AMERICAN
HONDA MOTOR CO., INC.
CASE NO.: 23NWCV02921
HEARING: 04/25/24
#7
I.
Defendants AMERICAN HONDA MOTOR COMPANY’s
Demurrer to Plaintiffs’ Complaint is OVERRULED.
II.
Defendants AMERICAN HONDA MOTOR COMPANY’s
Motion to Strike Portions of Plaintiffs’ Complaint is DENIED.
Opposing Party to give notice.
This “lemon law” action was filed by JOSEPH RHA and HANNA
RHA (“Plaintiffs”) on September 14, 2023. Plaintiff alleges that American Honda Motor
Company (“Defendant” or “Honda”) did not disclose and actively concealed defects
involving Honda’s Transmission Defect affecting Plaintiff’s 2019 Honda Odyssey
vehicle. (See e.g., Complaint ¶¶8, 18.)
Plaintiff’s Complaint asserts the following causes of action:
(1)
Violation of Song-Beverly Act – Breach of Express
Warranty;
(2)
Fraudulent Inducement -Concealment
Defendants generally demur to the fifth and sixth causes of action.
Second Cause of Action – Fraudulent Inducement (Concealment)
Defendants argue that Plaintiff’s second cause of action is barred by
the economic loss rule.
In Dhital v. Nissan North America, Inc., wherein the Court of
Appeal held that the plaintiff’s claim for fraudulent inducement (concealment)
was not barred by the economic loss rule (Id. (2022) 84 Cal.App.5th 828,
837.) Similar to the instant case, the Dhital plaintiffs alleged that
“Nissan, by intentionally concealing facts about the defective transmission,
fraudulently induced them to purchase a car.” (Id. at 838.). The Court
of Appeal ruled that “Robinson did not hold that any claims for
fraudulent inducement are barred by the economic loss rule. Quite the contrary,
the Robinson court affirmed that tort damages are available in contract
cases where the contract was fraudulently induced.” (Id. at 839.) “[A]
defendant’s conduct in fraudulently inducing someone to enter a contract is
separate from the defendant’s later breach of the contract or warranty
provisions that were agreed to.” (Id.)
Here, Plaintiff basis their claim on Defendant’s alleged presale
concealment, which is distinct from Defendant’s alleged subsequent breach of
its warranty obligations. Accordingly, based on the existing persuasive
authority— Dhital, the Court finds that the economic loss rule does not
bar Plaintiff’s claim. This
court is aware that this very issue is pending before the Supreme Court in Rattagan
v. Uber Tech., Inc. (Case No. S272113) and in Kia v. Superior Court
(Case No. S273170). Until the Supreme
Court states otherwise, this court will follow Dhital for its
“potentially persuasive value” (CRC Rule 8.1115(e)(1)), and finds that
Plaintiff’s claim is not barred by the Economic Loss Rule. The Court
proceeds to assess Defendant’s arguments related to the merits of Plaintiff’s
claim.
Fraudulent inducement is a viable tort claim under California
law. ‘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. Fraud in the inducement is a
subset of the tort of fraud. It ‘occurs when ‘the
promisor knows what he is signing but his consent is induced by fraud, mutual
assent is present and a contract is formed, which, by reason of the fraud, is
voidable.’” (Dhital v. Nissan North America, Inc. (2022) 84
Cal.App.5th 828, 838-839.)
Here, Plaintiffs allege at ¶¶ 43,
47, 64, 68 that Defendant concealed and failed to disclose facts relating to
the defects. ¶115 alleges scienter and
intent to induce reliance based on concealment.
¶129 alleges Plaintiffs’ resulting damages.
The court finds that the Complaint alleges sufficient prior knowledge at
this pleading stage. Less specificity is required if it appears from the nature of
allegations that defendant must necessarily possess full information, or if the
facts lie more in the knowledge of opposing parties. (Alfaro v. Community Housing Improvement
System & Planning Assn., Inc. (2009) 171 Cal.App.4th 1356,
1384-1385.)
Defendant also argues
that this claim is barred by the three year statute of limitations for fraud
claims, arguing that Plaintiff was aware of the purported fraud on January 26,
2019, but failed to file this action until September 14, 2023. Here, Plaintiffs
allege that Honda actively concealed the purported defect thus tolling the
statute of limitations. (e.g. Complaint ¶43.) These allegations are sufficient
to withstand demurrer. The running of the statute of limitations must appear
clearly and affirmatively from the dates alleged on the face of the complaint.
It is not enough that the complaint might be time-barred. It must necessarily
be time-barred on the facts alleged. (Marshall v. Gibson, Dunn &
Crutcher (1995) 37 Cal.App.4th 1397, 1403.)
The Demurrer to the second cause of action is OVERRULED.
The Motion to Strike punitive damages
is DENIED based on the Court’s ruling above.