Judge: Michael Shultz, Case: 22CMCV00314, Date: 2023-02-09 Tentative Ruling

Case Number: 22CMCV00314    Hearing Date: February 9, 2023    Dept: A

22CMCV00314 Dwayne Hamilton v. Tanya Hamilton

Thursday, February 9, 2023 at 8:30 a.m.

 

[TENTATIVE] ORDER SUSTAINING IN PART AND OVERRULING IN PART DEMURRER TO THE CROSS-COMPLAINT

 

I.            BACKGROUND

The complaint alleges that Plaintiff, Dwayne Hamilton (Dwayne) obtained an order from the Los Angeles Superior Court transferring four parcels of real property to Dwayne in a probate matter settling the Estate of Margie Lee Hamilton (Estate). Prior to this order, the parties, who are siblings, entered into an informal verbal agreement wherein Defendant, Tanya Hamilton, (Tanya) would collect the rental proceeds from tenants on the property and deposit it into the Estate’s account. Dwayne alleges he discovered that Tanya misappropriated rental income and acted as de facto landlord/owner of the properties without Dwayne’s knowledge. Dwayne alleges claims for conversion and private nuisance.

On October 31, 2022, Tanya filed a cross-complaint against Dwayne alleging claims for fraud, intentional and negligent interference with prospective economic advantage, breach of contract, and breach of implied-in-fact contract. Cross-Defendant Dwayne now demurs to all claims alleged in the cross-complaint.

II.            LEGAL STANDARDS

        A demurrer reaches defects that appear on the face of the pleading. The court considers the allegations and matters that are subject to judicial notice. All facts are accepted as true. Saunders v. Superior Court (1994) 27 Cal.App.4th 832, 837–838. A demurrer tests the legal sufficiency of the allegations. It does not test their truth, the plaintiff’s ability to prove them, or the possible difficulty in making such proof. Saunders v. Superior Court (1994) 27 Cal.App.4th 832, 840.

III.            CAUSES OF ACTION AT ISSUE

A.      Intentional misrepresentation, negligent misrepresentation, and fraud

1)      Allegations.

            All three causes of action are premised on the allegation that in 2014, pursuant to discussions between the parties, Dwayne assured Tanya that to speed up their mother’s probate matter, Tanya would sign an Irrevocable Assignment of Interest (“Assignment”) transferring the real property to Dwayne. Cross-complaint, ¶¶ 22-23. Dwayne allegedly promised that once the probate matter was completed and Dwayne refinanced the property, he would return to Tanya her interests in the real property. Cross-complaint, ¶ 24. Tanya had Dwayne sign a document entitled, “Reason for Signing the Irrevocable Assignment of Interest” on June 5, 2016 (“the June 2016 Document”). Cross-complaint, ¶ 25.

2)      Arguments.

        In his demurrer, Dwayne argues that it is impossible for Tanya to base the fraud claims on the June 2016 document because Tanya signed the Assignment on May 31, 2016, which precedes the June 2016 document. She could not have relied on the June 2016 document in deciding to sign the Assignment.

3)      Discussion.

        A claim for fraud requires facts to support the following elements: (1) a misrepresentation, (2) made with knowledge of its falsity, (3) Defendant intended to defraud Plaintiff, i.e., induce Plaintiff’s reliance, (4) Plaintiff justifiably relied on the misrepresentation, (5) causing damage. Nagy v. Nagy (1989) 210 Cal.App.3d 1262, 1268. A claim for false promise is a type of intentional misrepresentation, i.e., actual fraud.

        Contrary to Dwayne’s argument, the date of signing of the June 2016 document does not render the fraud claims defective. Tanya adequately alleges that the fraud claims are based on 2014 representations made by Dwayne that Tanya wished to have acknowledged in writing, hence the document’s title, “Reason for Signing the Irrevocable Assignment of Interest. Cross-complaint, ¶ 25.

        Dwayne correctly argues that Tanya is precluded from alleging a claim for negligent misrepresentation if Tanya also alleges that Dwayne intentionally and falsely promised to transfer the property back to Tanya.         An action for promissory fraud (or false promise) may lie where a defendant “fraudulently induces the plaintiff to enter into a contract." Service by Medallion, Inc. v. Clorox Co.(1996) 44 Cal.App.4th 1807, 1816. The action is one of deceit, which requires proof that the “defendant made a misrepresentation of fact or a promise without any intention of performing it.” Id. The same elements for intentional fraud apply in a claim for false promise, and every element must be specifically pleaded. Id.

        A claim for negligent misrepresentation on the other hand arises where a defendant makes false statements, honestly believing them to be true, but without reasonable grounds for such belief. Cicone v. URS Corp. (1986) 183 Cal.App.3d 194, 208. In support of this claim, Tanya alleges that Dwayne never had any intention of returning Tanya’s interests, which is the same as deceit, not an honest belief that the representation was true. Cross-complaint, ¶ 52. Therefore, the claim for negligent misrepresentation is defective as alleged. Tarmann v. State Farm Mut. Auto. Ins. Co. (1991) 2 Cal.App.4th 153, 159. [Wherein the court of appeal sustained demurrer to the claim for negligent misrepresentation given the claim for intentional misrepresentation and the refused to recognize a claim for “negligent false promise.”].

B.      Breach of contract and breach of implied-in-fact contract.

1)      Allegations.

            The contract claims are based on the June 2016 document, wherein the parties agreed that Tanya would transfer her interests in the real property to Dwayne to facilitate refinance of the property. Cross-complaint, ¶ 75. Tanya alleges she continued to provide upkeep and maintenance of the properties in reliance of Dwayne’s agreement with Tanya. Cross-complaint, ¶ 76-77.

2)      Arguments.

             Dwayne argues that the contract is not supported by consideration, and past performance cannot constitute consideration for a new agreement. The June 2016 document does not require a promise or performance from Tanya. There is no indication of mutual assent since the document is signed only by Dwayne.

             Tanya argues that the parties entered into an oral agreement where Plaintiff was to refinance the properties in exchange for Tanya transferring her interests to Dwayne. Upon completion of the refinance, Dwayne was to return Tanya’s interests. Cross-complaint ¶ 75. The contract claims are adequately alleged based on the parties’ oral agreement.  

3)      Discussion.

            The June 2016 document signed by Dwayne acknowledges that he entered into an agreement with his sister with respect to the temporary transfer of Tanya’s interests and the purpose of that transfer. Cross-complaint, Ex. A, ¶ 1. The document infers that the agreement was previously made. The Cross-Complainant alleges that the agreement occurred “circa 2014.” Cross-complaint, ¶ 23.

            The oral contract is supported by consideration. The elements of a claim for breach of contract are (1) the existence of a valid and existing contract between the parties, (2) plaintiff’s performance or excuse for non-performance, (3) defendant’s breach; and (4) resulting damage. Richman v. Hartley (2014) 224 Cal.App.4th 1182, 1186. A valid contract requires (1) parties capable of contracting; (2) their consent; (3) a lawful object; and, (4) sufficient cause or consideration." Civ. Code, § 1550.

        There are two requirements to find consideration: "[t]he promisee must confer (or agree to confer) a benefit or must suffer (or agree to suffer) prejudice … the second requirement is that the benefit or prejudice ‘must actually be bargained for as the exchange for the promise.’ ” Steiner v. Thexton (2010) 48 Cal.4th 411, 420-421. Here, Tanya alleges that she agreed to waive her beneficial share (prejudice) and assign her rights to the property to Dwayne who promised to refinance the property and upon its completion, return Tanya’s interest. Cross-complaint, ¶ 75. Tanya alleges that these discussions preceded her signing of the Assignment. Cross-complaint, ¶ 23.

        Even if the contract claims are allegedly based on the June 2016 document, the Court is not limited to Plaintiff’s theory of recovery in testing the sufficiency of their complaint. The Court “must determine if the factual allegations of the complaint are adequate to state a cause of action under any legal theory. The courts of this state have ... long since departed from holding a plaintiff strictly to the 'form of action' he has pleaded and instead have adopted the more flexible approach of examining the facts alleged to determine if a demurrer should be sustained.” Quelimane Co. v. Stewart Title Guaranty Co. (1998) 19 Cal.4th 26, 38–39.

C.       Intentional and negligent interference with prospective economic advantage.

1)      Allegations.

            Tanya alleges that she had an economic relationship with the tenants of the rental properties at issue that would have resulted in an economic benefit to her. Dwayne allegedly disrupted this relationship by harassing both Tanya and the tenants leading to difficulties in Tanya’s collection of rents. Cross-complaint ¶ 57-59.

            The claim for negligent interference with prospective economic advantage is based on the same facts but alleges Dwayne failed to act with reasonable care by not returning Tanya’s interests in the properties. Cross-complaint, ¶ 68-69.

2)      Arguments.

            Dwayne argues that this claim is barred by the two-year statute of limitations. Tanya alleges that Dwayne interfered beginning May 31, 2016. Therefore, the limitations period expired on May 31, 2018. Tanya filed the cross-complaint on October 31, 2022.

            Tanya argues that the interference claims did not accrue until the date of discovery, which occurred on April 1, 2022, when Dwayne cutoff all communication with Defendant. However, in Reply, Dwayne contends that Tanya knew or had reason to know of all underlying facts by July 9, 2018, at the latest.

3)      Discussion.

            Claims for intentional and negligent interference with prospective economic advantage is two years from the date the claim accrues. Guess, Inc. v. Superior Court (1986) 176 Cal.App.3d 473, 478. ["A number of California cases have held that tortious interference with a person's trade or business comes within the two-year limitation in section 339, subdivision (1), as an action upon an obligation or liability not founded upon an instrument in writing."].

            In order for the court to sustain demurrer to the complaint based on a statute of limitations defect, the defect must clearly and affirmatively appear on the face of the complaint. It is not enough that the complaint might be barred. Citizens for a Responsible Caltrans Decision v. Department of Transportation (2020) 46 Cal.App.5th 1103, 1117

            Dwayne contends that the interference claims accrued on May 31, 2016, when Tanya transferred her interests in the properties to Dwayne. However, the claims are based on Dwayne’s alleged interference in the economic relationship between Tanya and the tenants by harassing both Tanya and the tenants. Cross-complaint, ¶ 58-59, ¶ 62, 66-67. Dwayne also interfered with Tanya’s relationship with the tenants by deciding to keep the properties for himself and not returning Tanya’s interests precluding her ability to collect rents resulting in financial harm to Tanya. Cross-complaint, ¶ 68, 70-72. While the cross-complaint does not allege the date that the harassment began, Tanya alleges that on Dwayne, through his attorney, left the tenants with a “Notice of Ownership Change” on October 25th, 2022. Cross-complaint, ¶ 38, Ex. D.

        Based on these allegations, the interference claims have not expired. Dwayne has not demonstrated that the pleading clearly and affirmatively bars Cross-Complainant’s interference claims.

D.     Statutes of limitation on the fraud and contract claims.

1)      Fraud

            Fraud claims must be commenced within three years of the date the claim accrued. Code Civ. Proc., § 338 subd. (d). However, the claim is not deemed to have accrued until the discovery, by the aggrieved party, of the facts constituting the fraud. Id., subd. (d). Moreover, actual discovery does not include constructive knowledge imputed by law. Id., subdv (c)(3)(C)(i).    Dwayne argues the fraud claims are barred because Tanya should have known of the alleged fraud by March 2, 2018, when Dwayne completed the refinancing, completed the probate proceeding, and allegedly refused to return Tanya’s interests. Therefore, Dwayne argues that claims expired on June 11, 2021. The cross-complaint was filed on October 31, 2022.

        In opposition, Tanya alleges that the fraud claims are not barred since they accrued on the date Tanya discovered that the misrepresentations were false which occurred on April 1, 2022, when Dwayne cutoff all communications with Tanya.

        The cross-complaint does not clearly allege the date Tanya discovered that Dwayne’s representations concerning the return of Tanya’s interests were false. Thus, the pleading does not clearly and affirmatively establish that Tanya’s fraud claim is barred. Instead, Tanya affirmatively alleges that Dwayne cutoff all communication between himself and Tanya in April of 2022. Cross-complaint, ¶ 35. The three-year limitations period has not expired.

2)      Contract claims.

            The statute of limitations for claims arising from breach of an oral contract is two years. Code Civ. Proc., § 339. The claim accrues from the date of the promisor’s failure “to do the thing contracted for at the time and in the manner contracted.” Professional Collection Consultants v. Lauron (2017) 8 Cal.App.5th 958, 966. The cross-complaint does not clearly allege the date at which Dwayne failed to return Tanya’s interests as promised. Tanya does not allege the date at which she was informed that Dwayne removed her from the mortgage account, preventing Tanya from making mortgage payments. Cross-complaint, ¶ 29. However, she also alleges that Dwayne would add her to the mortgage account. Cross-complaint, ¶ 31. While the cross-complaint expressly alleges that the parties’ mother’s estate was finalized on March 2, 2018, the cross-complaint does not allege that Tanya learned on this date that Dwayne would not return Tanya’s interests. Cross-complaint, ¶ 32. The cross-complaint does affirmatively allege that Dwayne cut off all communications with Tanya on April 2022. Cross-complaint, ¶ 35. Therefore, the contract claims are not clearly barred.

 

IV.            CONCLUSION

            Based on the foregoing, the demurrer is sustained in part and denied in part. The Court SUSTAINS demurrer without leave to amend as to the second cause of action for negligent misrepresentation, which is precluded as a matter of law by the first and seventh causes of action for fraud. The Court OVERRULES demurrer to the first and seventh causes of action for fraud (promissory fraud) and intentional fraud, respectively; the third and fourth causes of action for intentional and negligent interference, respectively; and the fifth and sixth causes of action for breach of contract and implied-in-fact contract, respectively. Cross-Defendant is ordered to answer the cross-complaint withing 10 days.