Judge: Michelle Williams Court, Case: 21STCV44625, Date: 2022-09-07 Tentative Ruling

Case Number: 21STCV44625    Hearing Date: September 7, 2022    Dept: 74

21STCV44625           ARMANDO LIRA vs MARISELA SANDS

Plaintiff/Cross-Defendant Armando Lira’s Demurrer and Motion to Strike

TENTATIVE RULING:  Plaintiff and Cross-Defendant Armando Lira’s Demurrer to Defendants’ and Cross Complainants’ Cross-Complaint is SUSTAINED with leave to amend as to the first, second, fifth, sixth, and seventh causes of action and OVERRULED as to the third and fourth causes of action.  Cross-Defendant Armando Lira’s Motion to Strike Portions of the Cross-Complaint is DENIED.

Background

 

On December 6, 2021, Plaintiff Armando Lira filed this action against Marisela Sands, Nationstar Mortgage, LLC, and all unknown persons claiming any interest in the property. The complaint asserts causes of action for: (1) partition of real property; (2) unjust enrichment; and (3) accounting. The complaint alleges Plaintiff Lira and Defendant Sands own real property located at 727 Saybrook Avenue, Los Angeles, CA 90022 as joint tenants. Plaintiff and Defendant’s “mother transferred the interest in the real property to Plaintiff wherein Plaintiff was to refinance and provide a certain sum of money in the amount of $30,000/each for their interest in the Subject Property. Plaintiff has already provided to each of his seven (7) siblings half (1/2) of that interest and intends to provide each sibling the remaining half (1/2) when he is able to refinance the Subject Property once again to obtain the additional funds.”

 

On March 7, 2022, Marisela Sands, Hermelinda Olvera, Rosa Balderas, Dolores Lira Vasquez, Maria C. Delgado, and Jesus Jim Lira filed a cross-complaint against Armando Lira, Ma. Ema Lira Almanza, and all unknown persons claiming any interest in the property. The cross-complaint asserts causes of action for: (1) quiet title; (2) imposition of constructive trust; (3) fraud and deceit; (4) constructive fraud; (5) declaratory relief; (6) partition by appraisal; and (7) accounting.

 

Demurrer and Motion to Strike

 

On May 13, 2022, Cross-Defendant Armando Lira demurrer to each cause of action asserted in the cross-complaint arguing that the cross-complaint is not properly verified, and the claims violate the statute of frauds as well as the statute of limitations.

 

Cross-Defendant also moves to strike the exemplary damages allegations contained in paragraphs 35 and 39 as well as the prayer for relief.

 

Opposition

 

In opposition, Cross-Complainants contend the cross-complaint is properly verified, pleads facts demonstrating an exception to the statute of frauds as well as delayed discovery precluding the application of the statute of limitations, and the allegations are sufficient to support a claim for punitive damages.

 

Reply

 

In reply, Cross-Defendant argues Cross-Complainants have not demonstrated or alleged any exceptions to the statute of frauds or statute of limitations and failed to allege facts supporting their punitive damages claim.

 

Cross-Defendant Failed to Satisfy the Meet and Confer Requirements

 

Pursuant to Code of Civil Procedure sections 430.41 and 435.5, a demurrer and motion to strike must be accompanied by a meet and confer declaration.

 

Cross-Defendant did not file the required declaration in support of either the demurrer or motion to strike.

 

Demurrer

 

Standard

 

A demurrer for sufficiency tests whether the complaint states a cause of action. (Hahn v. Mirda (2007) 147 Cal.App.4th 740, 747.) When considering demurrers, courts read the allegations liberally and in context. In a demurrer proceeding, the defects must be apparent on the face of the pleading or via proper judicial notice. (Donabedian v. Mercury Ins. Co. (2004) 116 Cal.App.4th 968, 994.) “A demurrer tests the pleadings alone and not the evidence or other extrinsic matters. Therefore, it lies only where the defects appear on the face of the pleading or are judicially noticed. (Code Civ. Proc., §§ 430.30, 430.70.) At the pleading stage, a plaintiff need only allege ultimate facts sufficient to apprise the defendant of the factual basis for the claim against him. (Semole v. Sansoucie (1972) 28 Cal. App. 3d 714, 721.) A complaint need not allege evidentiary facts noting plaintiff’s proof. (C.A. v. William S. Hart Union High School Dist. (2012) 53 Cal.4th 861, 872.) A “demurrer does not, however, admit contentions, deductions or conclusions of fact or law alleged in the pleading, or the construction of instruments pleaded, or facts impossible in law.” (S. Shore Land Co. v. Petersen (1964) 226 Cal.App.2d 725, 732.)

 

A special demurrer to a complaint is appropriate when the grounds of the pleading are uncertain, ambiguous, or unintelligible. (Code Civ. Proc. § 430.10(f); Beresford Neighborhood Assn. v. City of San Mateo (1989) 207 Cal.App.3d 1180, 1191.) Courts typically disfavor demurrers based on uncertainty, which the court strictly construes even when the pleading is uncertain in some respects. (Khoury v. Maly’s of California, Inc. (1993) 14 Cal.App.4th 612, 616.)

 

If the demurrer is sustained, plaintiff must prove the possibility of cure by amendment. (Czajkowski v. Haskell & White, LLP (2012) 208 Cal.App.4th 166, 173 (citing Grinzi v. San Diego Hospice Corp. (2004) 120 Cal.App.4th 72, 78-79).) Leave to amend must be allowed where there is a reasonable possibility of successfully stating a cause of action. (Schulz v. Neovi Data Corp. (2007) 152 Cal.App.4th 86, 92.) 

 

The Cross-Complaint is Properly Verified

 

Cross-Defendant contends the cross-complaint is not properly verified because only two of the Cross-Complainants verified the cross-complaint. (Dem. at 2:18-26.) Pursuant to Code of Civil Procedure section 761.020, a quiet title complaint must be verified. (See e.g. Deutsche Bank National Trust Co. v. Pyle (2017) 13 Cal.App.5th 513, 524 (“The quiet title plaintiff must file a verified complaint.”).)

 

As argued by Cross-Complainants, only one of the Cross-Complainants must verify the pleading. (See e.g. Claiborne v. Castle (1893) 98 Cal. 30, 33; Brochtrup v. Intep (1987) 190 Cal.App.3d 323, 330 (“Where there are several parties, verification by one is sufficient.”).) Cross-Defendant appears to concede this point by not addressing verification in the reply.

 

The demurrer based upon the sufficiency of the verification is OVERRULED.

 

Statute of Frauds

 

Cross-Defendant contends the entire cross-complaint violates the statute of frauds. (Dem. at 3:1-25.) Civil Code section 1624 provides that certain enumerated “contracts are invalid, unless they, or some note or memorandum thereof, are in writing and subscribed by the party to be charged or by the party's agent.” Similarly, Probate Code section 15206 provides “[a] trust in relation to real property is not valid unless evidenced by one of the following methods: (a) By a written instrument signed by the trustee, or by the trustee's agent if authorized in writing to do so. (b) By a written instrument conveying the trust property signed by the settlor, or by the settlor's agent if authorized in writing to do so. (c) By operation of law.”

 

Cross-Defendant’s statute of frauds argument is directed at the entirety of the cross-complaint, but fails to cite any authority that would apply the contractual doctrine of the statute of frauds to bar tort claims for fraud, such as the third and fourth causes of action. In California, fraud causes of action are not barred by the statute of frauds. (See e.g. Tenzer v. Superscope, Inc. (1985) 39 Cal.3d 18, 31 (“The policies of the statute of frauds will not be subverted by affording plaintiffs who can prove actual fraud the opportunity to do so.”).) Accordingly, Cross-Defendant’s statute of frauds argument is inapplicable to the third and fourth causes of action.

 

The remainder of the causes of action are all based upon the contention that, despite the manner in which title was recorded, the property would be held “in trust for the benefit of Ana M. Lira’s children, Armando Lira, Marisela Sands Ma. Ema Lira Almanza, Hermelinda Olvera, Rosa Balderas, Dolores Lira Vasquez, Maria C. Delgado and Jesus Jim Lira which she intended as a gift to her children with the understanding that she would acquire a right to occupy the subject property until a time she was unable or of her passing.” (Cross-Compl. ¶¶ 10-11.)

 

In opposition, Cross-Complainants cite general authority regarding various grounds for avoiding the statute of frauds. (Opp. at 4:27-5:21.) However, Cross-Complainants solely argue they “fully performed the obligations required of them under the agreement.” (Opp. at 5:22-23.) Cross-Complainants cite their allegation that they “agreed to share equally in the upkeep and maintenance of the subject property which they continued to do, until prevented by Armando Lira’s breach of his duties as trustee of the property under the agreement as alleged herein.” (Cross-Compl. ¶¶ 12, 18.)

 

The Court agrees with Cross-Defendant’s arguments in reply that Cross-Complainants rendition of services, of an undefined character and amount for “upkeep and maintenance, does not bring the agreement outside the statute of frauds. In Shive v. Barrow (1948) 88 Cal.App.2d 838, the court found:

 

The oral agreements alleged were that plaintiffs would pay money, perform services, and procure the performance of services. The services were the making of improvements to the property and erecting a building thereon. No facts are alleged from which it could be concluded that the services were of such a peculiar character that it was or is practically impossible to estimate their value by any pecuniary standard. There is a long line of decisions in this state to the effect that the law gives plaintiffs an adequate remedy for breach of the agreement, or for the money advanced and for compensation for the services rendered, and that equity will not grant quasi-specific performance of the agreement when such remedies are available.

 

(Id. at 843–844.) Similarly, in Palmer v. Phillips (1954) 123 Cal.App.2d 291, the court held:

 

Plaintiffs contend, however, that they have alleged sufficient facts to obviate the bar of the statute. This contention is without substance. The allegations of the complaint disclose that in reliance on the alleged oral contract, plaintiffs performed miscellaneous services, some purely impersonal and others of an intimate and confidential nature, requiring a degree of self-discommoding in order to accommodate themselves to the specialized needs of the decedents. Ordinarily, in order to prevent unjust enrichment, the law provides a remedy wherein the reasonable value of such personal services may be recovered in an action against the estate of the deceased promisor based upon the theory of quantum meruit. [Citations]. However, the mere rendition of personal services is not sufficient to relieve a contract from the operation of the statute in an action for quasi-specific performance unless they are of “such peculiar, extraordinary, or exceptional character that it is impossible to estimate their value by any pecuniary standard or to adequately compensate for them in money [citations].” [Citation]. An examination of the allegations previously set out clearly manifests that the services performed are not of such unique or extraordinary character as would make them noncompensable in money; nor have plaintiffs subjected themselves to such a detrimental change of position as would work an unconscionable hardship to leave them to their legal remedy of quantum meruit.”

 

(Id. at 295–296.) The same is true here. Cross-Complainants merely allege the provision of upkeep and maintenance, which can be compensated by recovery for the reasonable value thereof.

 

In reply, Cross-Defendant also addresses authority related to estoppel, which is a broader, separate issue from full performance, not raised in the opposition. (See Byrne v. Laura (1997) 52 Cal.App.4th 1054, 1072 (“The doctrines of part performance and equitable estoppel are, in any event, separate grounds for avoiding a statute of frauds.”).)

 

The Court finds the allegations in the Cross-Complaint regarding the first, second, fifth, sixth, and seventh causes of action fall within the statute of frauds without sufficient allegations of demonstrating an exception thereto.

 

The demurrer is SUSTAINED with leave to amend as to the first, second, fifth, sixth, and seventh causes of action. The demurrer is OVERRULED as to the third and fourth causes of action.

 

Statute of Limitations

 

Cross-Defendant also argues the claims are barred by the statute of limitations based upon the following brief argument:

 

The Cross-Complaint states that the Property would not pass from the parties’ mother Ana M. Lira until after her passing. Cross-Complaint ¶¶ 10–11. Cross-Defendants also admit the contract was oral, therefore it is subject to a two year statute of limitations (Cal. Code Civ. Proc. § 339); Cross-Complaint ¶ 11. The Cross-Complaint fails to state that Ana M. Lira passed away less than two years before the purported agreement between the parties and therefore should be denied on this basis as well.

 

(Dem. at 4:1-7.)

 

“A demurrer on the ground of the bar of the statute of limitations will not lie where the action may be, but is not necessarily barred.... It must appear clearly and affirmatively that, upon the face of the complaint, the right of action is necessarily barred.... This will not be the case unless the complaint alleges every fact which the defendant would be required to prove if he were to plead the bar of the applicable statute of limitation as an affirmative defense.” (Lockley v. Law Office of Cantrell, Green, Pekich, Cruz & McCort (2001) 91 Cal.App.4th 875, 881.) 

 

As with the statute of frauds argument, Cross-Defendant seeks to apply the two-year statute of limitations for an oral contract claim to the third and fourth causes of action for fraud. Fraud claims are governed by an entirely separate statute providing a three-year statute of limitations. (Code Civ. Proc. ¶ 338(d).)

 

In opposition, Cross-Complainants note they allege they did not discover Cross-Defendant’s fraud and breach of the alleged agreement until July 13, 2021. (Opp. at 6:26-10:19; Cross-Compl. ¶¶ 22-23.)

 

“In order to rely on the discovery rule for delayed accrual of a cause of action, a plaintiff whose complaint shows on its face that his claim would be barred without the benefit of the discovery rule must specifically plead facts to show (1) the time and manner of discovery and (2) the inability to have made earlier discovery despite reasonable diligence.  In assessing the sufficiency of the allegations of delayed discovery, the court places the burden on the plaintiff to show diligence; conclusory allegations will not withstand demurrer.” (Fox v. Ethicon Endo-Surgery, Inc. (2005) 35 Cal.4th 797, 808.) “[A] plaintiff must allege facts showing the time and surrounding circumstances of the discovery and what the discovery was.” (Cansino v. Bank of America (2014) 224 Cal.App.4th 1462, 1472.) 

 

The Court agrees with Cross-Complainants that the allegations are sufficient to render the action timely. The Cross-Complaint alleges an agreement to convey the property on demand, (Cross-Compl. ¶¶ 11, 17), Cross-Defendant demanded that Sands “execute and record a deed naming him as full owner of the Subject Property” on July 13, 2021, (Id. ¶¶ 22, 23), Cross-Defendant concealed his true intent and no previous demand had been made upon him to convey the property. (Id. ¶ 23.) Nothing further is required at the pleading stage.

 

The demurrer based upon the statute of limitations is OVERRULED.

Motion to Strike

 

Cross-Defendant moves to strike paragraphs 35 and 39 as well as the prayers for relief related to exemplary damages.

 

Standard

 

Any party, within the time allowed to respond to a pleading may serve and file a notice of motion to strike the whole or any part thereof. (Code of Civ. Proc. § 435(b)(1); Cal. Rules of Court, rule 3.1322(b).) The court may, upon a motion or at any time in its discretion and upon terms it deems proper: (1) strike out any irrelevant, false, or improper matter inserted in any pleading; or (2) strike out all or any part of any pleading not drawn or filed in conformity with the laws of California, a court rule, or an order of the court. (Code Civ. Proc. § 436(a)-(b); Stafford v. Shultz (1954) 42 Cal.2d 767, 782.)

 

“In order to survive a motion to strike an allegation of punitive damages, the ultimate facts showing an entitlement to such relief must be pled by a plaintiff. [Citations.] In passing on the correctness of a ruling on a motion to strike, judges read allegations of a pleading subject to a motion to strike as a whole, all parts in their context, and assume their truth. [Citations.] In ruling on a motion to strike, courts do not read allegations in isolation. [Citation.]” (Clauson v. Superior Court (1998) 67 Cal.App.4th 1253, 1255.) “Pleading in the language of the statute is not objectionable when sufficient facts are alleged to support the allegation.” (Perkins v. Superior Court (1981) 117 Cal.App.3d 1, 6-7.)

 

Punitive Damages

 

Cross-Defendants failed to demur to the Cross-Complaint based upon the sufficiency of the allegations associated with the fraud claims. The Cross-Complaint alleges Cross-Defendant agreed to hold the property in trust for Cross-Complainants and convey the property on demand, (Cross-Compl. ¶¶ 10-11), Cross-Defendant had no intention of doing so, (Id. ¶¶ 23, 27-29), and Cross-Complainants relied upon the representation of their sibling to their detriment by contributing to the maintenance of the property. (Id. ¶¶ 12, 18, 28.)

 

Punitive damages are properly supported by an adequately stated claim for fraud. (Civ. Code § 3294(c)(3) (“‘Fraud’ means an intentional misrepresentation, deceit, or concealment of a material fact known to the defendant with the intention on the part of the defendant of thereby depriving a person of property or legal rights or otherwise causing injury.”); Stevens v. Superior Court (1986) 180 Cal.App.3d 605, 610 (“A fraud cause seeking punitive damages need not include an allegation that the fraud was motivated by the malicious desire to inflict injury upon the victim. The pleading of fraud is sufficient.”).)

 

The motion to strike is DENIED in its entirety.