Judge: Mark A. Young, Case: 21SMCV01472, Date: 2023-08-22 Tentative Ruling

Case Number: 21SMCV01472    Hearing Date: February 9, 2024    Dept: M

CASE NAME:           Strategic Legal Practices APC v. Consumer Law Experts PC, et al.

CASE NO.:                21SMCV01472

MOTION:                  Demurrer to the Third Amended Complaint

HEARING DATE:   2/9/2024

 

Legal Standard

 

            A demurrer for sufficiency tests whether the complaint states a cause of action. (Hahn v. Mirda (2007) 147 Cal.App.4th 740, 747.) When considering demurrers, courts read the allegations liberally and in context. In a demurrer proceeding, the defects must be apparent on the face of the pleading or via proper judicial notice. (Donabedian v. Mercury Ins. Co. (2004) 116 Cal.App.4th 968, 994.) A demurrer tests the pleadings alone and not the evidence or other extrinsic matters. Therefore, it lies only where the defects appear on the face of the pleading or are judicially noticed. (CCP §§ 430.30, 430.70.) At the pleading stage, a plaintiff need only allege ultimate facts sufficient to apprise the defendant of the factual basis for the claim against him. (Semole v. Sansoucie (1972) 28 Cal. App. 3d 714, 721.) A “demurrer does not, however, admit contentions, deductions or conclusions of fact or law alleged in the pleading, or the construction of instruments pleaded, or facts impossible in law.” (S. Shore Land Co. v. Petersen (1964) 226 Cal.App.2d 725, 732, internal citations omitted.)

 

            A special demurrer for uncertainty is disfavored and will only be sustained where the pleading is so bad that defendant cannot reasonably respond—i.e., cannot reasonably determine what issues must be admitted or denied, or what counts or claims are directed against him/her. (CCP § 430.10(f); Khoury v. Maly’s of Calif., Inc. (1993) 14 Cal.App.4th 612, 616.) Moreover, even if the pleading is somewhat vague, “ambiguities can be clarified under modern discovery procedures.” (Ibid.)

 

            “Liberality in permitting amendment is the rule, if a fair opportunity to correct any defect has not been given.” (Angie M. v. Superior Court (1995) 37 Cal.App.4th 1217, 1227.) It is an abuse of discretion for the court to deny leave to amend where there is any reasonable possibility that plaintiff can state a good cause of action. (Goodman v. Kennedy (1976) 18 Cal.3d 335, 349.) The burden is on plaintiff to show in what manner plaintiff can amend the complaint, and how that amendment will change the legal effect of the pleading. (Id.)

 

Analysis

 

Defendant Beck demurs to the Third Amended Complaint’s (TAC) fourth cause of action for a violation of Penal Code § 502. Defendant Beck argues that he was authorized to access the data in the course and scope of his employment and did not have to bypass or circumvent security and penetrate levels of software.

 

Penal Code section 502 states, in relevant part:

 

(a) It is the intent of the Legislature in enacting this section to expand the degree of protection afforded to individuals, businesses, and governmental agencies from tampering, interference, damage, and unauthorized access to lawfully created computer data and computer systems. The Legislature finds and declares that the proliferation of computer technology has resulted in a concomitant proliferation of computer crime and other forms of unauthorized access to computers, computer systems, and computer data…

 

(b) For the purposes of this section, the following terms have the following meanings:

(1) “Access” means to gain entry to, instruct, cause input to, cause output from, cause data processing with, or communicate with, the logical, arithmetical, or memory function resources of a computer, computer system, or computer network.

[…]

(10) “Injury” means any alteration, deletion, damage, or destruction of a computer system, computer network, computer program, or data caused by the access, or the denial of access to legitimate users of a computer system, network, or program.

 

(c) Except as provided in subdivision (h), any person who commits any of the following acts is guilty of a public offense:

[…]

(2) Knowingly accesses and without permission takes, copies, or makes use of any data from a computer, computer system, or computer network, or takes or copies any supporting documentation, whether existing or residing internal or external to a computer, computer system, or computer network.

 

[…]

 

(e)(1) In addition to any other civil remedy available, the owner or lessee of the computer, computer system, computer network, computer program, or data who suffers damage or loss by reason of a violation of any of the provisions of subdivision (c) may bring a civil action against the violator for compensatory damages and injunctive relief or other equitable relief.

 

[…]

(h) Subdivision (c) does not apply to punish any acts which are committed by a person within the scope of lawful employment. For purposes of this section, a person acts within the scope of employment when the person performs acts which are reasonably necessary to the performance of their work assignment.

(2) Paragraph (3) of subdivision (c) does not apply to penalize any acts committed by a person acting outside of their lawful employment, provided that the employee's activities do not cause an injury, to the employer or another, or provided that the value of supplies or computer services which are used does not exceed an accumulated total of two hundred fifty dollars ($250).

(Emphasis added.)

 

Beck allegedly accessed SLP’s computer system for the unauthorized purpose of downloading thousands of SLP documents from hundreds of its client case files, including training materials [and] other documents, which he copied to a Google drive, his personal computer and other repositories and shared with CLE and Anvar. (TAC ¶¶ 5, 21-23.) Plaintiff alleges that Beck breached the Beck Agreement by downloading SLP’s Proprietary Information and Documents without authorization from the SLP computer system to his Google drive, personal computer and other repositories during his employment and after leaving SLP until 9:00 on his last day of employment, and that he did so for an unauthorized purpose – namely, sharing them with CLE, using them at CLE, and engaging in activities and to compete with SLP using these materials. (TAC ¶¶ 37-40.) Plaintiff claims that Beck violated section 502 by knowingly accessing and without permission copying and making use of data from Plaintiff’s computer system, and diverting that data to himself and third parties. (TAC ¶¶ 58-61.) These allegations mirrors Penal Code section 502(c)(2)’s language.

 

One issue is whether Beck’s conduct violated section 502(c), or whether the exemption in section 502(h) applies to Beck’s access and copying of SLP’s data. Plaintiff alleges that Beck accessed and copied the data outside the scope of his employment with Plaintiff. The Second District discussed this exemption in the case of Chrisman v. City of Los Angeles as follows:

 

Broadly speaking, subdivision (h) has two subparts that under certain conditions prohibit criminally punishing an employee who misuses an employer's computer. The first subpart applies to an employee's computer misuse within the scope of his employment. It states:

 

“Subdivision (c) [the punishment provision on which respondents rely] does not apply to punish any acts which are committed by a person within the scope of his or her lawful employment. For purposes of this section, a person acts within the scope of his or her employment when he or she performs acts which are reasonably necessary to the performance of his or her work assignment.” (§ 502, subd. (h)(1).)

 

It is undisputed that appellant was on duty when he misused department computers. Respondents argue appellant was not, however, acting within the scope of his employment because he had no legitimate job-related reason for his computer inquiries. But respondents define “scope of employment” too narrowly. They suggest it covers only legitimate job-related conduct, rendering acts that violated department rules outside the scope of employment. Generally speaking, however, showing that an employee violated an employer's rules does not determine whether the employee acted within the scope of employment . . ..

 

(Chrisman v. City of Los Angeles (2007) 155 Cal. App. 4th 29, 36.) After reviewing “scope of employment” caselaw, the Chrisman court concluded that “an employer's disapproval of an employee's conduct does not cast the conduct outside the scope of employment. If the employer's disapproval were the measure, then virtually any misstep, mistake, or misconduct by an employee involving an employer's computer would, by respondents' reasoning, be criminal.” (Id. at 37; citing Mary M. v. City of Los Angeles (1991) 54 Cal.3d 202 [Supreme Court held that a police officer in uniform and driving a marked police car was acting within the scope of his employment when he pulled over a drunken driver but instead of arresting her, took her home and raped her]; Perez v. Van Groningen & Sons, Inc. (1986) 41 Cal.3d 962 [child was hurt riding alongside his uncle in uncle’s employer’s tractor in violation of employer’s rules; uncle still found to be within the scope of employment because he was working for his employer while operating the tractor]; Mahru v. Superior Court (1987) 191 Cal.App.3d 545 [defendant-employee found exempt under former version of section 502 where employee retaliated out of spite against a customer of his employer by altering a computer's software to prevent the customer from using the employer's computer].) 

Here, Beck’s access was not within the scope of his employment even as broadly defined by caselaw. Beck’s access and copying of such data was not reasonably necessary for Beck to perform his work assignments as an attorney at Plaintiff’s firm, but rather for the purpose of establishing a competing law firm.  (TAC ¶¶ 3, 11.)

Plaintiff must also plead an injury. Notably, subdivision (h)(2) provides an exemption to subdivision (c)(3) for “any acts committed by a person acting outside of his or her lawful employment, provided that the employee's activities do not cause an injury” defined by the statute. An injury in this context does not mean any form of damage, but “any alteration, deletion, damage, or destruction of a computer system, computer network, computer program, or data caused by the access, or the denial of access to legitimate users of a computer system, network, or program.” (Pen. Code § 502(b)(10).)  Here, however, Plaintiff has brought this action under subdivision (c)(2), and therefore, the limitations set forth above would not apply.

 

Furthermore, subdivision (e)(1) permits “any other civil remedy available . . . who suffers damage or loss by reason of a violation of any of the provisions of subdivision (c) may bring a civil action . . . for compensatory damages and injunctive relief or other equitable relief.”  The limitations on damages urged by Defendant are not supported by a plain reading of the statute.  Here, Plaintiff has properly alleged damages under the statute.

 

Accordingly, the demurrer is OVERRULED.  Defendant to file an answer within 20 days.