Judge: Peter A. Hernandez, Case: 24STCV15575, Date: 2025-02-05 Tentative Ruling

Case Number: 24STCV15575    Hearing Date: February 5, 2025    Dept: 34

Specially Appearing Defendant Kent Security Services, Inc.’s Motion to Quash Service is CONTINUED ninety (90) days.

 

Background

 

            On June 21, 2024, Plaintiff Bianca Pulliam (“Plaintiff”) filed a PAGA Representative Action complaint against Defendants Kent Security Services, Inc. and Kent Security of California, Inc. (“Defendant”).

 

            On December 23, 2024, Defendant Kent Security Services, Inc. (“KSS”) filed this Motion to Quash Service and an answer to Plaintiff’s complaint. On January 23, 2025, Plaintiff filed an opposition. On January 29, 2025, KSS filed a reply.

 

Legal Standard

 

“A defendant, on or before the last day of his or her time to plead or within any further time that the court may for good cause allow, may service and file a notice of motion . . . [t]o quash service of summons[.]” (Code Civ. Proc., § 415.10(a).) Generally, a responsive pleading is due within thirty days after service of the complaint. (Code Civ. Proc., § 412.20(a)(3).) “A defendant, . . . may serve and file a notice of motion…to quash service of summons on the ground of lack of jurisdiction of the court over him or her.” (Cal. Code Civ. Proc., §¿418.10(a)(1).)

Discussion

Request for Judicial Notice

Plaintiff’s request for judicial notice is granted. Judicial notice may be taken of “[f]acts and propositions that are not reasonably subject to dispute and are capable of immediate and accurate determination by resort to sources of reasonably indisputable accuracy.” (Evid. Code §§ 452, subd. (c) and (h).) This court may also take judicial notice of the records of any court of record of the United States. (Evid. Code §§ 452, subd. (d).)

Evidentiary Objections

            KSS’s evidentiary objections are overruled.

Personal Jurisdiction

            KSS moves to quash service of Plaintiff’s summons and complaint for lack of personal jurisdiction. (Motion, at p. 1.)

“California courts may exercise personal jurisdiction on any basis consistent with the Constitutions of California and the United States. (Code Civ. Proc., § 410.10.)” (Pavlovich v. Superior Court (2002) 29 Cal.4th 262, 268.) “The exercise of jurisdiction over a nonresident defendant comports with these Constitutions ‘if the defendant has such minimum contacts with the state that the assertion of jurisdiction does not violate “‘traditional notions of fair play and substantial justice.’”’ [Citations.]” (Ibid.)

“Personal jurisdiction may be either general or specific.” (Pavlovich, supra, 29 Cal.4th at pp. 268-269.) An individual is subject to general jurisdiction in the state of their domicile; while for a corporation it is where it is “fairly regarded as home.” (Goodyear Dunlop Tires Operations, S.A. v. Brown (2011) 564 U.S. 915, 924.) This is where the corporation’s contacts are “so ‘continuous and systematic’ as to render [the defendant] essentially at home in the forum state.” (Daimler AG v. Bauman (2014) 571 U.S. 117, 139.) In Goodyear and Daimler AG, for corporations, the U.S. Supreme Court held that general jurisdiction exists only in the defendant’s (1) state of incorporation and (2) principal place of business. (Goodyear, supra, 564 U.S. at p. 294; Daimler AG, supra, 571 U.S at p. 137.)  

KSS contends that no constitutional basis exists for the court to exercise general personal jurisdiction over it as KSS is registered to do business in Florida, does not maintain an agent for service of process in California, does not maintain offices in California, and does not have a business license or pay takes in California. (Motion, at p. 7.) Additionally, KSS argues that Defendant Kent Security of California, Inc.’s (“KCA”) operations in California cannot be imputed to KSS for purposes of personal jurisdiction as KCA is not a subsidiary of KSS. (Id., at p. 8.)

            In opposition, Plaintiff argues that KSS’s contacts in California are substantial, continuous, and systematic as KSS maintains a website that directly references its services in California and maintains an office in Los Angeles. (Opp., at p. 10.) Additionally, Plaintiff argues that KSS markets KCA’s services in California and KSS recruits employees for KCA to work in California. (Id., at p. 11.) Lastly, Plaintiff argues that under the representative service doctrine, general jurisdiction exists as KSS uses KCA to expand KSS’s marketplace into California. (Ibid.)

The court finds that Plaintiff has not presented evidence to demonstrate that general jurisdiction of KSS exists as KSS’ state of incorporation and its principal place of business is in Florida. (Neuman Decl., ¶ 5; see Goodyear, supra, 564 U.S. at p. 294; Daimler AG, supra, 571 U.S at p. 137.)

The California Supreme Court has held that three requirements must be met before specific jurisdiction may be exercised: (a) defendant purposefully availed himself of the forum benefits, (b) the controversy is related to or arises from defendant’s contacts with California, and (c) the assertion of jurisdiction would comport with fair play and substantial justice. (Pavlovich, supra, 29 Cal.4th 262, 269.) “A plaintiff opposing a defendant’s motion to quash service has the burden of establishing factor Nos. (1) (the defendant’s purposeful availment) and (2) (lawsuit relates to the defendant’s contacts with state).” (People ex rel. Harris v. Native Wholesale Supply Co. (2011) 196 Cal.App.4th 357, 362, citing Bridgestone Corp. v. Superior Court (2002) 99 Cal.App.4th 767, 774].) “If the plaintiff does so, the burden then shifts to the defendant to show factor No. (3), that the exercise of jurisdiction would be unreasonable.” (Ibid.)  

KSS argues that it has not purposely availed itself of the rights and protections of California as KSS operates its business entirely out of Florida. (Motion, at p. 8.) KSS also argues that Plaintiff cannot impute KCA’s contacts with California onto KSS to justify the court’s specific jurisdiction over KSS as Plaintiff fails to establish a theory of agency between Defendants. (Id., at p. 9.) KSS contends that KSS does not exercise any control over KCA, and the success of KSS’ business does not rely on KCA’s services as Defendants are two different entities. (Ibid.) Additionally, KSS argues that there is no substantial link between KSS, California, and the injuries suffered by Plaintiff. (Id., at p. 10.) KSS contends that KSS never employed Plaintiff nor exercised control over Plaintiff’s employment with KCA which is the basis for Plaintiff’s complaint. (Ibid.) Lastly, KSS argues that exercising specific personal jurisdiction over KSS would not comport with the notions of fair play and substantial justice. (Ibid.)

In opposition, Plaintiff argues that KSS had contacts with California as KSS marketed services, recruited multiple employees, and litigated in California for years. (Opp., at p. 12.) Additionally, Plaintiff argues that KSS maintains a website that reference services in California and maintains an office in Los Angeles. (Ibid.) Plaintiff also contends that KSS provides contracts to employees in California, including arbitration agreements. (Id.; RJN, Exh. C, F-G.) Plaintiff contends that KSS’ corporate officers hold similar positions within KCA and work out of the same corporate office in Florida. (Id., at p. 13.) Plaintiff also argues that Plaintiff’s claims are substantially connected to KSS’ California contacts in that Plaintiff’s causes of action result from the work she performed in California and KSS solicits customers for those services, recruits employees, and enters into employment contracts with individuals in California. (Ibid.) Lastly, Plaintiff claims that exercising jurisdiction over KSS is reasonable. (Id., at p. 14.)

The court finds that Plaintiff has failed to carry her burden of establishing by a preponderance of the evidence that KSS has sufficient contacts with California that relate to Plaintiff’s claim to justify jurisdiction. Plaintiff has failed to produce evidence to establish that the alleged misconduct in the complaint is related to or arises out of KSS’ contacts with California. Furthermore, Plaintiff does not explain how this controversy relates to California when Plaintiff believed that she was a KSS employee but does not show evidence supporting that contention. Previous litigation in California involving KSS and employment contracts with others do not establish a connection between KSS, California, and the claims made by Plaintiff.

Jurisdictional Discovery

“A plaintiff attempting to assert jurisdiction over a nonresident defendant is entitled to an opportunity to conduct discovery of the jurisdictional facts necessary to sustain its burden of proof[.]” (Hardell v. Vanzyl (2024) 102 Cal.App.5th 960, 975-976; Goehring v. Superior Court (1998) 62 Cal.App.4th 894.) This court has “discretion to continue the hearing on a motion to quash service of summons for lack of personal jurisdiction to allow the plaintiff to conduct discovery on jurisdictional issues.” (HealthMarkets, Inc. v. Superior Court (2009) 171 Cal.App.4th 1160, 1173.) However, “In order to prevail on a motion for a continuance for jurisdictional discovery, the plaintiff should demonstrate that discovery is likely to lead to the production of evidence of facts establishing jurisdiction.” (In re Automobile Antitrust Cases I & II (2005) 135 Cal.App.4th 100, 127) 

Plaintiff argues that she presented sufficient evidence to show that further discovery may lead to the production of evidence of facts establishing jurisdiction. (Opp., at p. 14.) Specifically, Plaintiff contends that discovery could show that KSS employed Plaintiff. (Id., at p. 13.) Additionally, Plaintiff contends that Plaintiff will seek discovery regarding Defendants’ policies, interlocking directors and officers, representations made by or about KSS and KCA, services performed for one entity by the other, assistance provided by one entity to the other, interactions and communications between employees of each entity, ownership or use of trademarks or logos, involvement in collective bargaining, the capitalization of the entities, intercompany financial transactions, and the like which will allow Plaintiff to establish jurisdiction. (Id., at p. 16.)

            As such, the court finds that Plaintiff’s evidence shows that targeted and focused discovery may lead to production of evidence of admissible facts establishing jurisdiction. Therefore, KSS’ motion to quash service of summons and complaint for lack of personal jurisdiction is continued for ninety (90) days to permit time to conduct targeted and focused jurisdictional discovery. Supplemental opposition and reply are to be filed on statutory time.

Conclusion

Specially Appearing Defendant Kent Security Services, Inc.’s Motion to Quash Service is CONTINUED ninety (90) days.