Judge: Lee W. Tsao, Case: 23NWCV03541, Date: 2024-02-22 Tentative Ruling
Case Number: 23NWCV03541 Hearing Date: February 22, 2024 Dept: C
MELLO-NAVEJAS v. FORD
MOTOR COMPANY
CASE NO.: 23NWCV03541
HEARING: 02/22/24
#5
Defendants FORD MOTOR COMPANY’s and NORM REEVES FORD’s
Demurrer to Plaintiff’s Complaint is OVERRULED in part and SUSTAINED with 15
days leave to amend in part.
Moving Party to give notice.
This “lemon law” action was filed by KATHLEEN MELLO-NAVEJAS (“Plaintiff”)
on November 2, 2023. Plaintiff alleges that Ford Motor Company (“Defendant” or “Ford”) did
not disclose and actively concealed defects involving Ford’s Transmission
Defect affecting Plaintiff’s 2018 Ford Expedition vehicle. (See e.g., Complaint
¶¶9, 36.) Defendant Norm Reeves Ford
Superstore (“Defendant” or “Norm”) is alleged to be the dealership wherein
Plaintiff purchased the subject vehicle.
Plaintiff’s Complaint asserts the following causes of action:
(1)
Violation of Cal. Civ. Code §1793.2
(2)
Violation of Cal. Civ. Code §1793.2(b)
(3)
Violation of Cal. Civ. Code §1793.2(A)(3)
(4)
Breach of the Implied Warranty of Merchantability
(5)
Fraudulent Inducement – Concealment
(6)
Negligent Repair
(7)
Violation of the Maguson-Moss Warranty Act
Defendants generally demur to the fifth and sixth causes of action.
Fifth Cause of Action – Fraudulent Inducement (Concealment)
Defendants argue that Plaintiff’s fifth 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, Plaintiff alleges at ¶¶ 36,
67-71 that Defendant concealed and failed to disclose facts relating to the
defects. ¶¶ 65-66 alleges scienter and
intent to induce reliance based on concealment.
¶71 alleges Plaintiff’s 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.)
The Demurrer to the fifth cause of action is OVERRULED.
Sixth Cause of Action – Negligent
Repair
Defendant argues that Plaintiff’s sixth cause of action, as alleged, is
barred by the economic loss rule.
The economic loss
rule provides that “where a purchaser’s expectations in a sale are frustrated
because the product he bought is not working properly, his [or her] remedy
is said to be in contract alone, for he [or she] has suffered only economic
losses.” (Robinson Helicopter Company
v. Dana Corporation (2004) 34 Cal.4th 979, 988.) “Tort damages have been permitted in contract
cases where a breach of duty directly causes physical injury; for breach of the
covenant of good faith and fair dealing in insurance contracts; for wrongful
discharge in violation of fundamental public policy; or where the contract was
fraudulently induced…. in each of these cases, the duty that gives rise to tort
liability is either completely independent of the contract or arises from
conduct which is both intentional and intended to harm.” (Robinson, supra, 34 Cal.4th at 989–990.)
In Robinson, the California Supreme Court carved out
a “narrow” and “limited” exception to the economic loss rule, holding that “a
defendant's affirmative misrepresentations on which a plaintiff relies
and which expose a plaintiff to liability for personal damages independent of
the plaintiff's economic loss” is excluded from the economic loss rule. (Robinson, supra, 34 Cal.4th at 993.)
Here,
Plaintiff alleges a claim for negligent repair which does not fall within the
narrow exceptions carved out by the California Supreme Court in Robinson. Plaintiff does not allege that Defendant
engaged in any intentional misconduct or made any affirmative
misrepresentations. As alleged, the economic loss rule bars Plaintiff’s
recovery under the sixth cause of action.
The
demurrer to the sixth cause of action is SUSTAINED with 15 days leave to amend.
In
the interests of justice, 15 days leave to amend is GRANTED.