Judge: Michael Shultz, Case: 23CMCV01435, Date: 2024-04-02 Tentative Ruling

Case Number: 23CMCV01435    Hearing Date: April 2, 2024    Dept: A

23CMCV01435 Susan Boyd v. City of Compton, et al.

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

 

I.        BACKGROUND

      The complaint alleges that Plaintiff slipped and fell on an uneven sidewalk. Plaintiff alleges claims for negligence and premises liability.

II.      ARGUMENTS

Defendant, City of Compton (“City”) demurrers to the second cause of action for premises liability on grounds Plaintiff has not alleged facts to support all elements of the claim and with required particularity.

Plaintiff argues that the claim for dangerous condition of public property is adequately alleged.  Alternatively, Plaintiff asks for leave to amend.

In reply, City argues that the complaint alleges conclusions of law and fact, which are improper.

III.    LEGAL STANDARDS

      A demurrer tests the sufficiency of a complaint as a matter of law and raises only questions of law. (Schmidt v. Foundation Health (1995) 35 Cal.App.4th 1702, 1706.) In testing the complaint’s sufficiency, the court must assume the truth of the properly pleaded factual allegations as well as facts that can be reasonably inferred from those expressly pleaded facts. The court may also consider matters properly subject to judicial notice. (Blank v. Kirwan (1985) 39 Cal.3d 311, 318.)

      The court may not consider contentions, deductions, or conclusions of fact or law. (Moore v. Conliffe (1994) 7 Cal.4th 634, 638.) Plaintiff is required to allege facts sufficient to establish every element of each cause of action. (Rakestraw v. California Physicians Service (2000) 81 Cal.App.4th 39, 43.) Where the complaint fails to state facts sufficient to constitute a cause of action, courts should sustain the demurrer. Code Civ. Proc., § 430.10(e); (Zelig v. County of Los Angeles (2002) 27 Cal.4th 1112, 1126.)

      Sufficient facts are the essential facts of the case "with reasonable precision and with particularity that is sufficiently specific to acquaint the defendant with the nature, source, and extent of his cause of action.” (Gressley v. Williams (1961) 193 Cal.App.2d 636, 643-644.)  Whether the Plaintiff will be able to prove the pleaded facts is irrelevant. (Stevens v. Superior Court (1986) 180 Cal.App.3d 605, 609–610.)

      A demurrer may also be sustained if a complaint is “uncertain.” Uncertainty exists where a complaint’s factual allegations are so confusing, they do not sufficiently apprise a defendant of the issues it is being asked to meet. (Williams v. Beechnut Nutrition Corp. (1986) 185 Cal.App.3d 135, 139, fn. 2; Code Civ. Proc., § 430.10(f).)

 

IV.    DISCUSSION

      To state a cause of action against a public entity under Government Code section 835, a plaintiff must allege facts to establish (1) the existence of a dangerous condition that caused injury to plaintiff, (2) the condition created a reasonably foreseeable risk of injury sustained by the plaintiff (3) and either the public entity had actual or constructive notice of the dangerous condition or an employee of the public entity created the condition. (Gov. Code, § 835; Brenner v. City of El Cajon (2003) 113 Cal.App.4th 434, 439.)

      Plaintiff checked all of the appropriate boxes on the Judicial Council form complaint that state the ultimate facts supporting elements of the claim. Additionally, Plaintiff alleges “sufficiently detailed and specific” facts to provide a factual context for the claim. (People ex rel. Dept. of Transportation v. Superior Court (1992) 5 Cal.App.4th 1480, 1484.) To be “demurrer proof” a plaintiff must allege essential ultimate facts to state a claim. (Id.) The complaint meets that threshold.

      Plaintiff alleges that Defendants (all government entities) owned, maintained, managed, and controlled the pavement/sidewalk where Plaintiff fell. Defendants allegedly failed to barricade the area and/or warn of the dangerous condition. The allegations that Defendants had actual or constructive notice or created the condition is set forth on the form. (Complaint, ¶ 4.)

      Defendant contends that Plaintiff did not allege the degree of unevenness of the sidewalk. (Dem. 5:18-21.) However, Defendant does not cite authority requiring that allegation. The City cites Stathoulis v. City of Montebello (2008) 164 Cal.App.4th 559 which discussed the degree of dangerous of the condition, however, at issue was whether the condition was trivial, which was a triable issue supporting denial of the motion for summary judgment/ adjudication. (Stathoulis at 569.) The summary judgment standard differs from the standard applied to a demurrer.

      Here, Plaintiff alleges that the condition was dangerous, which the Court accepts as true for purposes of a demurrer. (Gov. Code, § 830.2 [" A condition is not a dangerous condition within the meaning of this chapter if the trial or appellate court, viewing the evidence most favorably to the plaintiff, determines as a matter of law that the risk created by the condition was of such a minor, trivial or insignificant nature in view of the surrounding circumstances that no reasonable person would conclude that the condition created a substantial risk of injury… .”].)

      The City contends Plaintiff must identify the employee acting within the scope of employment, whose alleged act or omission caused Plaintiff’s injury. (Dem. 7-10.) City does not cite authority requiring identification of employees and in fact, the allegation is not required. (C.A. v. William S. Hart Union High School Dist. (2012) 53 Cal.4th 861, 872. ["… the District cites no statute or decision requiring a plaintiff to specify at the pleading stage which of the defendant's employees committed the negligent acts or omissions for which a public entity is allegedly liable under section 815.2. To survive a demurrer, the complaint need only allege facts sufficient to state a cause of action; each evidentiary fact that might eventually form part of the plaintiff's proof need not be alleged.”].)

V.      CONCLUSION

Based on the foregoing, demurrer to the complaint is OVERRULED. Defendant is ordered to answer within 10 days.