Judge: Olivia Rosales, Case: 22NWCV00561, Date: 2022-12-20 Tentative Ruling

Case Number: 22NWCV00561    Hearing Date: December 20, 2022    Dept: SEC

CREDITORS ADJUSTMENT BUREAU, INC. v. QOL SERVICES, INC.

CASE NO.:  22NWCV00561

HEARING: 12/20/22 @ 10:30 AM

JUDGE:  OLIVIA ROSALES

 

#5

TENTATIVE RULING

 

Defendants QOL Service, Inc. and Inclusive Employment Services’ demurrer is OVERRULED.  Defendants are ORDERED to file and serve its Answer within 10 days.

 

Opposing Party to give NOTICE.

 

 

Defendants QOL Service, Inc. and Inclusive Employment Services (collectively, “QOL”) demurs to the 1st – 4th causes of action on the grounds that the court lacks subject matter jurisdiction and the doctrine of primary jurisdiction.

 

The Complaint alleges that Plaintiff’s Assignor, State Compensation Insurance Fund (“SCIF”), is owed a debt of $126,614.14, $32,374.77, and $241,582.44 on three workers compensation insurance policies that SCIF provided to Defendants QOL Services, Inc. and Inclusive Employment Services.  Based thereon, the Complaint asserts causes of action for:

 

1.    Breach of Contract

2.    Open Book Account

3.    Account Stated

4.    Reasonable Value

 

PRIMARY JURISDICTION

 

The primary jurisdiction doctrine "applies where a claim is originally cognizable in the courts, and comes into play whenever enforcement of the claim requires the resolution of issues which, under a regulatory scheme, have been placed within the special competence of an administrative body; in such case the judicial process is suspended pending referral of such issues to the administrative body for its views (Farmers Insurance Exchange v. Superior Court (1992) 2 Cal.4th 377, 390.)  ''No rigid formula exists for applying the primary jurisdiction doctrine." (Farmers, supra, at p. 391.) It "advances two related policies: it enhances court decisionmaking and efficiency by allowing courts to take advantage of administrative expertise, and it helps assure uniform application of regulatory laws." (Farmers, supra, at p. 391.) Thus, courts have invoked the doctrine where the Insurance Commissioner "has at his disposal 'a pervasive and self-contained system of administrative procedure' to deal with the precise questions" raised by the complaint and where the "resolution of these questions mandates exercise of expertise presumably possessed by the Insurance Commissioner, and poses a risk of inconsistent application of the regulatory statutes if courts are forced to rule on such matters without benefit of the view of the agency charged with regulating the insurance industry." (Farmers, supra, at pp. 396, 398.)  

 

The Insurance Commissioner is best suited to initially determine whether the “regulations pertaining to eligibility have been faithfully adhered to by an insurer."  (Id. at p. 399; see also Jonathan Neil & Associates, Inc. v. Jones (2004) 33 Cal.4th 917, 931-932 - “Primary jurisdiction”… applies where a claim is originally cognizable in the courts, and comes into play whenever enforcement of the claim requires the resolution of issues which, under a regulatory scheme, have been placed within the special competence of an administrative body; in such a case the judicial process is suspended pending referral of such issues to the administrative body for its views.”)  The court stays the proceedings and refers the issues to the Department of Insurance. (Jonathan Neil & Associates, Inc. v. Jones (2004) 33 Cal.4th 917, 935.)

 

Judicial Notice is taken of the Matter of Appeal of A-Brite Blind & Drapery Cleaning (Ex. 3), Michael Reynolds Enterprise, Inc. v. State Compensation Insurance Fund and American Jetter & Plumbing, Inc. v. State Compensation Insurance Fund (Exs. 4-5) cases.

 

"[I]n determining whether it is appropriate to issue a stay of judicial proceedings in order to permit administrative action under the primary jurisdiction doctrine" the court must confine its analysis "to the complaint as written."  (Farmers, supra, at p. 398.)  Although Defendant contends that SCIF used the same erroneous modifier as in the A-Brite administrative action, this fact does not appear on the face of the Complaint in this action.  Unlike Reynolds (19STCV05738) and Jetter (19STCV36307), where the Complaints specifically allege irregularities in SCIF’s tier modifiers, the complaint in this action was filed by Creditors Adjustment Bureau, Assignor of SCIF, for contract damages.  The Complaint alleges legally sufficient contract claims.

 

Accordingly, QOL’s demurrer cannot be sustained based on the primary jurisdiction doctrine because the Complaint, as written, alleges legally sufficient claims.  Thus, the demurrer is OVERRULED. 

 

QOL has not filed a Cross-Complaint or Answer, alleging SCIF’s erroneous modifier calculations.  Once these factual allegations appear on the face of the pleadings in this court, QOL may bring a motion to stay based on the primary jurisdiction doctrine. 

 

Defendants are ORDERED to file and serve their Answers within 10 days.