Judge: Michael Shultz, Case: 23CMCV00066, Date: 2024-07-02 Tentative Ruling

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Case Number: 23CMCV00066    Hearing Date: July 2, 2024    Dept: A

23CMCV00066 Makila Moorer v. City of Compton, Los Angeles Department of Water & Power

Tuesday, July 2, 2024, at 8:30 a.m.

 

[TENTATIVE] ORDER DENYING MOTION FOR SANCTIONS FILED BY DEFENDANT, CITY OF COMPTON

 

I.        BACKGROUND

       The complaint alleges that Plaintiff fell into a “sidewalk/utility access hole” allegedly, owned and maintained by Defendants. Plaintiff alleges the cover over the hole was in poor condition. (Complaint, ¶¶ 3-5.) Plaintiff alleges a cause of action for dangerous condition of public property. (Gov Code § 835.)

II.      ARGUMENTS

       Defendant, City of Compton (“City”) argues that the court should impose sanctions of dismissal as well as monetary sanctions against Plaintiff for failing to dismiss the complaint after the City gave Plaintiff conclusive evidence that it did not own, operate, control, or maintain the utility box at issue. Plaintiff did not conduct an objectively reasonable inquiry before filing the complaint. it is factually and legally without merit.

       In opposition, Plaintiff argues that the declaration of the City’s Street Superintendent did not sufficiently establish that Defendant did not own, control, maintain, or operate the area where Plaintiff fell. The declaration is conclusory. The utility box was on the City’s sidewalk, which supports that City is a proper party.

       Plaintiff argues that she attempted to obtain evidence through written discovery and by deposition relevant to the utility box cover, however, Defendant responded to all written discovery served on March 17, 2024, with “boilerplate objections” and refused to produce a person most qualified for deposition.  (Samer Habbas decl., ¶¶ 10, 19.) Therefore, Defendant has not met its burden of showing the complaint is frivolous.

       The City did not file a reply brief by Tuesday, June 25, 2024, five court days before the hearing. (Code Civ. Proc., § 1005(b).)

III.    LEGAL STANDARDS

       An attorney who signs and presents a pleading to the court certifies that the pleading has factual and legal merit.  (Code Civ. Proc., § 128.7.) The attorney certifies that the pleading is not being presented primarily for an improper purpose such as to harass or to cause unnecessary delay or increase in the cost of litigation. (Id. subd. (b).)

       By signing the pleading, an attorney also certifies that the claims are warranted by existing law and that the claims have evidentiary support or would likely have evidentiary support after a reasonable investigation. (Id.) The court may impose sanctions for violations of subdivision (b). (Id.)

       City has complied with the statute’s “safe harbor” provision by first serving the motion on Plaintiff and allowing 21 days for Plaintiff to withdraw the improper pleading and avoid sanctions. (Id. at subd. (c)(1).)

 

IV.    DISCUSSION

       The court applies an objective standard to determine whether the attorney submitting the pleading acted reasonably in investigation and asserting the claim. (Bockrath v. Aldrich Chemical Co., Inc. (1999) 21 Cal.4th 71, 82.) A claim is objectively unreasonable if “any reasonable attorney would agree that [it] is totally and completely without merit.” (Peake v. Underwood (2014) 227 Cal.App.4th 428, 440.)

       Plaintiff asserts one cause of action for dangerous condition of public property. (Gov. Code, § 835.) To prevail on the claim, a plaintiff must plead and prove (1) the existence of a dangerous condition on the public property at the time of the injury; (2) the condition proximately caused the injury; (3) the condition created a reasonably foreseeable risk of the kind of injury sustained; and either a public employee created the dangerous condition while in the scope of employment or the entity had actual or constructive notice of the dangerous condition. (Gov. Code, § 835.)

       To be liable, the public entity must either own or control the property containing the dangerous condition "but do not include easements, encroachments and other property that are located on the property of the public entity but are not owned or controlled by the public entity.” (Gov. Code, § 830.)

       Contrary to the City’s argument neither the photograph of the defect nor Mr. Timmons’ declaration “conclusively establish” that the City did not own, control, or maintain the concrete utility box. (Mot. 6:24-28.) Mr. Timmons speculates that the utility box was not the City’s property because of the lack of markings attributable to the City and concludes that the City did not maintain, operate, or control the subject location. (Timmons Decl. ¶ 5-7.)

       The lack of markings does not necessarily speak to the City’s control over the location. The photograph of the broken utility box does not show its location relative to the public sidewalk, whether within the sidewalk or adjacent to the sidewalk. (Mot., Ex. 6.) The relevant issue is whether the City had notice of the condition and failed to correct it; "it is not relieved of its responsibility in this regard merely because the condition was created or maintained by a property owner who might also be liable to pedestrians for injuries resulting therefrom."(Marsh v. City of Sacramento (1954) 127 Cal.App.2d 721, 724.)

       Moreover, public property may be considered dangerous if a condition on adjacent property “exposes those using the public property to a substantial risk of injury." (Hedayatzadeh v. City of Del Mar (2020) 44 Cal.App.5th 555, 563.) Without more, Defendant’s evidence does not obviate the City’s duty with respect to the condition of the utility box. City has not met its burden of showing that Plaintiff’s counsel violated Section 128.7 subd. (b).

       Plaintiff requests imposition of sanctions against Defendant for filing a frivolous motion. The court has discretion to award a successfully opposing party attorney’s fees if the motion for sanctions that was brought primarily for an improper purpose, such as to cause unnecessary delay or increase the cost of litigation. The motion "shall itself be subject to a motion for sanctions. It is the intent of the Legislature that courts shall vigorously use its sanctions authority to deter that improper conduct or comparable conduct by others similarly situated. (Code Civ. Proc., § 128.7.)

       Attorney fees may be awarded to the prevailing party on a section 128.7 motions only “if warranted.” (Musaelian v. Adams (2011) 197 Cal.App.4th 1251, 1257.) While the filing of the motion is also subject to the requirements of statute, requests for attorney’s fees for successfully defending against a the motion “are infrequently granted where the motion was not clearly frivolous, filed for an improper purpose, or not well-grounded in fact or law.” (Musaelian at 1258.) There is insufficient evidence to make those findings.

 

V.      CONCLUSION

       Based on the foregoing, Defendant’s motion for sanctions is DENIED. Plaintiff’s request for imposition of sanctions against Defendant is also DENIED.