Judge: Michael Shultz, Case: 22CMCV00505, Date: 2024-03-15 Tentative Ruling

INSTRUCTIONS: If the parties wish to submit on the tentative ruling and avoid a court appearance on the matter, the moving party must:

1. Contact the opposing party and all other parties who have appeared in the action and confirm that each will submit on the tentative ruling.

2. No later than 4:00 p.m. on the court day before the hearing, call the Courtroom (310-761-4302) advising that all parties will submit on the tentative ruling and waive hearing; and

3. Serve notice of the Court's ruling on all parties entitled to receive service.

If this procedure is followed, when the case is called the Court will enter its ruling on the motion in accordance with its tentative ruling. If any party declines to submit on the tentative ruling, then no telephone call is necessary, and all parties should appear at the hearing. If there is neither a telephone call nor an appearance, then the matter may either be taken off calendar or ruled on. 

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Case Number: 22CMCV00505    Hearing Date: March 15, 2024    Dept: A

22CMCV00505 Chatman V. Hammond

Friday, March 15, 2024, at 8:30 a.m.

 

[TENTATIVE] ORDER DENYING REQUEST FOR DEFAULT JUDGMENT

 

       The complaint alleges claims for slander and slander per se arising from statements allegedly made by Defendant in the course of a prior proceeding for a domestic violence restraining order alleged as Case No. 22CMRO00933. (Complaint, ¶ 7.) The Clerk entered default against Defendant on February 28, 2023. Plaintiff now seeks judgment of $35,000.

       The court last reviewed Plaintiff’s request for court judgment filed on February 21, 2023, and rejected the request for Plaintiff to submit a completed request. Plaintiff filed a request for court judgment on February 1, 2024, and a proposed order.

       A defendant’s failure to answer a complaint admits all matters well pleaded in the complaint. (Kim v. Westmoore Partners, Inc. (2011) 201 Cal.App.4th 267, 281). Therefore, the complaint must be examined. (Carlsen v. Koivumaki (2014) 227 Cal.App.4th 879, 899–900).

       The complaint does not allege an actionable claim because it is barred by the litigation privilege. The Civil Code defines a “privileged publication” as one made “[i]n any … judicial proceeding … .” (Civ. Code, § 47, (b)(2)). Under those circumstances, the privilege is absolute and applies regardless of malice. (Jacob B. v. County of Shasta (2007) 40 Cal.4th 948, 955). However, the privilege does not apply in cases of malicious prosecution. (Jacob B. at 960).

       The complaint does not allege facts supporting a claim for malicious prosecution of a civil proceeding. To prevail on such a claim, Plaintiff must plead and prove that Defendant commenced the prior action, the action terminated in Plaintiff’s favor, the action was brought without probable cause, and was initiated with malice. (Bertero v. National General Corp. (1974) 13 Cal.3d 43, 50.) A claim is unsupported by probable cause “only if any reasonable attorney would agree that the claim is totally and completely without merit.” (Parrish v. Latham & Watkins (2017) 3 Cal.5th 767, 776.).

       Plaintiff has not alleged facts to support that the prior proceeding terminated in Plaintiff’s favor and was brought without probable cause. The Court, on its own motion, takes judicial notice of the Court’s records in Case No. 22CMRO00933. (Code Civ. Proc., § 452 subd. (d).)  The Case Information reflects that on January 24, 2023, the Hon. Alfred A. Coletta granted the request for a restraining order brought by Syadia Hammond, Defendant herein. (Ord. 1/24/23.) The disposition precludes Plaintiff from alleging a claim for malicious prosecution because the proceeding did not terminate in Plaintiff’s favor.

       Based on the foregoing, the Request for Court Judgment is DENIED. As Plaintiff has not alleged a well-pleaded complaint capable of being cured, the action is DISMISSED.