Judge: Margaret L. Oldendorf, Case: 22AHCV00880, Date: 2023-11-03 Tentative Ruling
Case Number: 22AHCV00880 Hearing Date: November 3, 2023 Dept: P
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES
NORTHEAST DISTRICT
|
Plaintiff, vs. Edna
Soto Serrano, and Does 1-50, inclusive,
Defendants. |
) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) |
[TENTATIVE]
ORDER DENYING DEFENDANT’S MOTION TO RECLASSIFY Date: November 3, 2023 Time: 8:30 a.m. Dept.: P |
I. INTRODUCTION
On January 1, 2023, Plaintiff Sandra Ardon (Ardon)
filed her first amended complaint against Defendant Edna Soto Serrano (Serrano),
for negligence. Ardon alleges that on October 22, 2020, Serrano caused a
collision between their two vehicles. Ardon alleges she suffered injuries as a
result of the accident, and sues for damages.
On June 6, 2023, Serrano filed her answer. On
October 6, 2023, Serrano filed the instant Motion to Reclassify Case to Limited
Jurisdiction. Ardon filed an Opposition on October 16, 2023. Serrano filed a
Reply on October 20, 2023.
Before the Court is Serrano’s Motion
to Reclassify from Unlimited to Limited jurisdiction. Serrano urges that the
case is incorrectly classified as unlimited as the amount in controversy is
necessarily $25,000.00 or less. For the reasons that follow, the motion to
reclassify is DENIED.
II. LEGAL
STANDARD
Code of Civil Procedure § 403.040 allows a party to file a
motion for reclassification of an action within the time allowed for that party
to amend the initial pleading or respond to the initial pleading. (Code Civ. Proc., § 403.040(a).) If the motion is made after the time for the
party to amend the pleading or respond to a complaint, the motion may only be
granted if (1) the case is incorrectly classified; and (2) the party shows
good cause for not seeking reclassification earlier. (Code Civ. Proc. § 403.040(b).)
In Walker v. Superior Court (1991) 53
Cal.3d 257, 262, the California Supreme Court held that a matter may be
reclassified from unlimited to limited only if it appears to a legal certainty
that the plaintiff’s damages will necessarily be less than $25,000. (Walker v. Superior Court (1991) 53
Cal.3d 257.) If there is a possibility
that the damages will exceed $25,000.00, the case cannot be transferred to
limited. (Ibid.) This high standard is
appropriate in light of “the circumscribed procedures and recovery available in
the limited civil courts.” (Ytuarte v. Superior Court (2005)
129 Cal.App.4th 266, 278.)
In Ytuarte, the Court of Appeal examined
the principles it set forth in Walker
and held that “the court should reject the plaintiff’s effort to reclassify the
action as unlimited only when the
lack of jurisdiction as an ‘unlimited’ case is certain and clear.” (Ytuarte,
supra, 129 Cal.App.4th at 279 (emphasis added).) Nevertheless, the plaintiff must present
evidence to demonstrate a possibility that the damages will exceed $25,000.00
and the trial court must review the record to determine “whether a judgment in
excess of $25,000.00 is obtainable.” (Ibid.)
III. ANALYSIS
Serrano
seeks to reclassify this action as a limited civil action on the grounds that before
discovery was received, counsel did not “have any information pertaining to the
plaintiff’s alleged damages in the matter.” (Motion ¶ 9.) Counsel became aware
of the alleged amount of damages when Ardon served her responses to Serrano’s
form interrogatories. (Motion ¶ 8.)
Serrano’s
counsel states that until Plaintiff Ardon filed her responses to Serrano’s
discovery requests, Serrano was unaware of the amount of alleged damages in
this case. (Bhatia Decl. ¶ 9.) On August 24, 2023, Serrano served her first
sets of form and special interrogatories on Ardon. (Bhatia Decl. ¶ 3.) On
September 25, 2023, Ardon served her responses on Serrano. (Bhatia Decl. ¶ 4.)
In response to Form Interrogatory 6.4, requesting information as to medical
treatment sought because of the incident, Ardon responded that she sought $605.00
of care from Brentview Urgent Care on 10/23/20 and $395.00 of care from
Alhambra Health Clinic on 12/11/20. (Motion, Exh. A, p.29: 27-2, p. 30: 1-12.)
Secondly,
Serrano urges that “Besides the special damages, the only other potential
recoverable item of damage in this case is general damages, which, given the
amount of plaintiff’s alleged special damages, will not bring the value of this
case over the jurisdictional limit for an unlimited jurisdiction action of
$25,000.” (Motion p.7: 24-26, see also Reply, p.4: 26-28.) Serrano does not
support this contention with any additional evidence. To the extent that
Serrano is urging that the total amount in controversy is necessarily less than
$25,000.00, this is insufficient to prove to a “legal certainty” that the total
damages, factoring in general damages, will be less than $25,000.00. (Walker v. Superior Court (1991) 53
Cal.3d 257.)
Ardon
opposes this motion because “Plaintiff’s discovery responses are not ‘good
casue [cause]’ for Defendant’s delay.” (Opposition, p. 3: 17-19.) To the extent
that Ardon is arguing that Serrano did not adequately demonstrate good cause
for not bringing the motion to reclassify earlier, this is insufficient.
In
addition, Ardon opposes the Motion because “Plaintiff continues to have these
complaints [her injuries from the accident] to date.” (Opposition p.4: 24-25.) Additionally,
Ardon urges that she “was recommended for more treatment [which] she will
acquire to relieve her suffering.” (Opposition, p.4: 26-27.) Thus, plaintiff
urges that the case was not incorrectly classified. (Opposition, p.5: 3.)
The
Court finds that Serrano has demonstrated good cause for not seeking
reclassification earlier. The information as to what care plaintiff Ardon
sought after the accident, and how much the care cost, was not known to Serrano
before discovery responses were received. However, Serrano has not demonstrated
how Ardon’s total potential recovery would necessarily be less than $25,000.00.
Even if the entirety of special damages is $1,000.00, this does not foreclose
Ardon from seeking and obtaining a total of more than $25,000.00, as the cost
of continuing care and general damages is unknown. There is a possibility that
the damages will exceed $25,000.00.
IV. CONCLUSION
AND ORDER
For the foregoing reasons, Defendant Edna Soto Serrano’s
Motion to Reclassify Case to Limited Jurisdiction is DENIED. Plaintiff Ardon is
ordered to give notice.
Dated:
_______________________________
MARGARET L. OLDENDORF
JUDGE
OF THE SUPERIOR COURT