Judge: Michael Shultz, Case: 23STCV06266, Date: 2025-05-01 Tentative Ruling

Case Number: 23STCV06266    Hearing Date: May 1, 2025    Dept: 40

23STCV06266 Samantha Gerlach v. Brett Hazard

Thursday, May 1, 2025

 

[TENTATIVE] ORDER GRANTING MOTION FOR LEAVE TO FILE AN AMENDED COMPLAINT

 

                                                                                              I.         BACKGROUND

      Plaintiff alleges that she rents residential real property from Defendant, who permitted uninhabitable conditions to persist at the property. Defendant allegedly began harassing and retaliating against Plaintiff, who denied Defendant’s request for “cash for keys.” Plaintiff alleges five causes of action for:

1.     Breach of the common law duty of care

2.     Retaliation in violation of Civ. Code, § 1942.5

3.     Breach of the covenant of quiet enjoyment

4.     Violation of Tenant Anti-Harassment Ordinance

5.     Unfair Business practices       

                                                                                               II.        ARGUMENTS

A.     Motion filed February 21, 2025.

      Plaintiff requests leave to file a first amended complaint to add a claim for unlawful rent overcharge in violation of Los Angeles Municipal Code § 151.10, supported by facts of Defendant’s service of a defective rent increase notice, and Defendant’s continued demand to collect the increased rent. Plaintiff proposes to add supplemental authority for the prayer for attorney’s fees and a prayer for declaratory relief.

      Plaintiff argues that through the course of discovery, Defendant produced a copy of a notice of rent increase dated January 6, 2020 . At his deposition on March 6, 2024, Defendant testified that he served the notice on January 6, 2020, and that he thereafter continued to demand, collect, and retain rent from the Plaintiff, although the notice of rent increase was defective.

      Plaintiff contends that no new discovery should be required, since the facts pertaining to the new cause of action concern documents and testimony that have already been exchanged. Plaintiff does not anticipate that a continuation of trial will be necessary.

B.     Opposition filed April 18, 2025, by Vanderford & Ruiz

      Defendant argues that Plaintiff unreasonably delayed in making this motion. Plaintiff’s counsel’s “unintentional oversight” in making the motion is insufficient to overcome the prejudice to Defendant. The new claims are barred by the three-year statute of limitations. Plaintiff did not comply with procedural rules for filing this motion. Defendant will suffer prejudice if the court grants leave to amend.

C.     Opposition and joinder filed April 18, 2025, by Dignity Law Group.

      This opposition incorporates the opposition filed by Vanderford & Ruiz, also Defendant’s counsel, and adds that Plaintiff concedes in her own declaration that there could be an increased need to conduct further discovery. Discovery will close four days before this motion is heard. Continuous accrual applies to avoid the statute of limitations because Defendant continued to charge Plaintiff more than the maximum allowable rent each month. The continuing violations doctrine also applies to avoid the limitations bar.

D.     Reply filed April 23, 2025.

      Absent prejudice, the motion should be granted. Otherwise, Plaintiff will file a new lawsuit for one cause of action for illegal rent increase. The statute of limitations does not apply because a defective rent increase is wholly void and a nullity for all purposes.

                                                                                       III.       LEGAL STANDARDS

      Leave to amend is permitted at the court’s discretion upon any terms that may be just. (Code Civ. Proc., § 473 subd. (a)(1).) The statute is liberally construed to permit amendment of the pleadings “unless an attempt is made to present an entirely different set of facts by way of the amendment.” (Atkinson v. Elk Corp. (2003) 109 Cal.App.4th 739, 760.)

      If the motion is timely made and the granting of the motion will not result in prejudice to the opposing party, it is error to refuse permission to amend. (Morgan v. Superior Court of Cal. In and For Los Angeles County (1959) 172 Cal.App.2d 527, 530.) Where denial of the motion will result in a party being deprived of the right to assert a meritorious cause of action, “it is not only error but an abuse of discretion”. (Id.) The liberal policy permitting amendment at any stage of the proceedings, up to and including trial, "should be applied only ‘[w]here no prejudice is shown to the adverse party”. (Atkinson at 761.)

                                                                                                IV.       DISCUSSION

A.     Procedural requirements.

      Plaintiff substantially complied with the procedures required to request leave to amend. Cal Rules of Court, Rule 3.1324 subd. (a).)  Plaintiff states what allegations are proposed to be added and/or deleted and where, by page, paragraph, and line number. (Id.) The amendment will add a new cause for violation of laws barring rent increase which Plaintiff’s counsel discovered upon receipt of Defendant’s discovery responses in July of 2023, and confirmed at Defendant’s deposition on March 6, 2024. (Hong decl., ¶¶ 2-3.) Plaintiff’s counsel did not move to amend the pleading earlier until additional counsel became a handling attorney in February 2025. (Hong decl., ¶ 10.)

B.     The existence of prejudice or lack thereof.

      Defendant has not shown that substantial prejudice will result if Plaintiff adds the new claim. Defendant relies in part on Magpali v. Farmers Group, Inc. (1996) 48 Cal.App.4th 471. However, in that case, the new cause of action "would have changed the tenor and complexity of the complaint from its original focus.” (Magpali at 487.) Witnesses had not yet been identified, a jury was impaneled, and a trial continuance was necessary to permit opposing party to depose new witnesses. The case is factually distinguishable. (Id. at 488.)

      Here, the additional cause of action does not “change the tenor” of the case as it arises from Defendant’s alleged misconduct with respect to Plaintiff’s tenancy and adds one additional type of violation. Municipal Code § 151.10 of the Rent Stabilization Ordinance makes it unlawful to demand rent in excess of the maximum rent or maximum adjusted rent in violation of the Code. (LAMC 151.10.)

      Defendant does not identify any additional discovery he requires and will be precluded from obtaining if the amendment were allowed. The claim is based on Defendant’s issuance of a January 2020 notice for rent increase as admitted in Defendant’s responses to discovery and to which he testified at his deposition. (Hong decl., ¶¶ 2-3.)

      If there is no prejudice to the opposing party, only slight evidence is needed. Doubts are resolved in favor of the party seeking relief in furtherance of the policy that the law strongly favors trial and disposition on the merits. (Mink v. Superior Court, (1992) 2 Cal.App.4th 1338, 1343, [“We will more carefully scrutinize an order denying relief than one which permits a trial on the merits.”].)

C.     Statute of limitations.

      Defendant has not established that this claim is clearly barred. A claim based on a liability created by statute is three years. (Code Civ. Proc., § 338). The proposed amendment alleges that while notice of the increase was issued January 6, 2020, Defendant “continuously demanded, collected, and retained unlawfully increased rent since February 1, 2020.” (Prop. (FAC ¶ 74.) Defendant cites Foxborough v. Van Atta (1994) 26 Cal.App.4th 217 which arose from alleged attorney malpractice. (Id.) That case considered a single act of alleged malpractice and held that where the malpractice results in a loss of a right, remedy, or interest, there has been actual injury which is not tolled by subsequent events. (Id. at  227.)

      The “continuing violations” doctrine permits a plaintiff to recover for unlawful practices occurring outside the statute of limitations period if that conduct was "(1) similar or related to the conduct that occurred within the limitations period; (2) the conduct was reasonably frequent; and (3) the conduct had not yet become permanent. " (Jumaane v. City of Los Angeles (2015) 241 Cal.App.4th 1390, 1402.)

      The “continuous accrual” doctrine applies under circumstances where there are recurring invasions of the same right, each of which can trigger their own statute of limitations.  (Aryeh v. Canon Business Solutions, Inc. (2013) 55 Cal.4th 1185, 1198.) The principle seeks to correct inequities that would result where "parties engaged in long-standing misfeasance would thereby obtain immunity in perpetuity from suit even for recent and ongoing misfeasance. In addition, where misfeasance is ongoing, a defendant's claim to repose, the principal justification underlying the limitations defense, is vitiated." (Gilkyson v. Disney Enterprises, Inc. (2016) 244 Cal.App.4th 1336, 1342.)

      The doctrine applies where an obligation arises on a recurring basis, such as a case involving periodic payments. (State of California ex rel. Metz v. CCC Information Services, Inc. (2007) 149 Cal.App.4th 402, 418.) The reasoning is that each new breach of an obligation provides all elements of a claim and can then be treated as an independently actionable wrong with its own limitations period for recovery. "(Aryeh v. Canon Business Solutions, Inc. (2013) 55 Cal.4th 1185, 1199.)  If the harm arose out of a single transaction, however, the doctrine does not apply. (Id.)

      Here, the amended pleading does not allege a wrong arising from a single transaction. Rather, Defendant allegedly continued to demand increased rent in violation of the Municipal Code. Given these theories, Defendant has not shown that the new cause of action is affirmatively barred. (Citizens for a Responsible Caltrans Decision v. Department of Transportation (2020) 46 Cal.App.5th 1103, 1117; Marshall v. Gibson, Dunn & Crutcher (1995) 37 Cal.App.4th 1397, 1398, [In the context of a demurrer to the pleading, the court can only sustain if the limitations defect “clearly and affirmatively appear[s] on the face of the complaint."].)

V.   CONCLUSION

      Based on the foregoing, Plaintiff’s motion is GRANTED. Plaintiff is ordered to file the proposed amended pleading at the conclusion of today’s hearing.

 

 





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