Judge: Ralph C. Hofer, Case: 24NNCV00339, Date: 2024-08-30 Tentative Ruling

Case Number: 24NNCV00339    Hearing Date: August 30, 2024    Dept: D

TENTATIVE RULING

 

Calendar:         8                                             

Date:                                                                                       8/30/2024                   

Case No:                                                                                 24 NNCV00339                      Trial Date:       None Set

Case Name:     Chen v. Annavee, Inc., et al.  

 

DEMURRERS (2)

MOTION TO STRIKE

                                                                               

Moving Party:            Defendant Annavee Wingy Wong Kim

Defendant Annavee, Inc.       

Responding Party:       Plaintiff Wangxia Chen      

 

RELIEF REQUESTED:        

             Sustain demurrer to fourth, fifth, sixth, and twelfth causes of action of First Amended Complaint

             Strike punitive damages, request for PAGA penalties    

 

CAUSES OF ACTION:         from First Amended Complaint   

1)      Unlawful Failure to Pay Overtime Compensation     v.  All Defendants

2)      Failure to Provide Meal Breaks                      v.  All Defendants

3)      Failure to Provide Rest Breaks                       v.  All Defendants

4)      Inaccurate Wage Statements                       v.  All Defendants

5)      Unfair Business Practices                             v.  All Defendants

6)      Violation of the Rules on Tips and Gratuities       v.  All Defendants

7)      Split Shift                                                        v.  All Defendants

8)      Age Discrimination                                         v.  All Defendants

9)      Constructive Wrongful Termination and Retaliation  v.  All Defendants  

10)  Violation of Labor Code Section 558.1          v.  Kim

11)  Violation of Labor Code Section 1198.5        v.  All Defendants

12)  Violation of Labor Code Section 1174.5     v.  All Defendants

 

SUMMARY OF FACTS:

            Plaintiff Wanxia Chen alleges that defendant Annavee Inc. is a California corporation doing business as Chang’s Garden (Chang’s Garden), and that in 2006, defendant Annavee Wingyi Wong Kim hired plaintiff as a server in Chang’s Garden.

 

            Plaintiff alleges that while plaintiff served as a server at defendants’ establishment, Chang’s Garden, from September 2021 until December 3, 2022,    plaintiff suffered a series of employment violations.  The FAC alleges that defendants began treating plaintiff differently as she aged, deliberately reducing her hours to favor younger servers. When plaintiff raised concerns about age-based discrimination, it is alleged that defendants responded by further cutting plaintiff’s hours, ultimately forcing her to resign on December 3, 2022.

 

            The FAC alleges that plaintiff also faced various wage and hour violations, including improper tip distribution, non-payment for overtime hours, inadequate meal and rest break periods, and the failure to provide plaintiff with accurate wage statements.  Plaintiff alleges that these actions collectively demonstrate a clear pattern of discrimination, retaliation, and disregard for fair labor practices.    Plaintiff alleges that defendant Kim should be held accountable for specific labor violations, given her roles in ownership, operations and/or management within Chang’s Garden, and bears responsibility as the employer of plaintiff for the Labor Code violations.  

 

ANALYSIS:

Procedural

Meet and Confer—Plaintiff failed to Meet and Confer

The declaration of counsel submitted with the moving papers indicates that plaintiff has failed to respond to defendants’ counsel’s efforts to meet and confer prior to the filing of the demurrer and motion to strike. 

 

Specifically, the declaration of counsel indicates that plaintiff’s counsel has failed to respond to two written meet and confer correspondences, each of which requested plaintiff’s counsel’s availability for a telephonic meet and confer conference and provided a written summary of grounds for the demurrers and motion to strike.  [Perry Decl., paras. 3-9, Ex. A]  

 

CCP § 430.41 requires that both parties meet and confer:

“(a) Before filing a demurrer pursuant to this chapter, the demurring party shall meet and confer in person or by telephone with the party who filed the pleading that is subject to demurrer for the purpose of determining whether an agreement can be reached that would resolve the objections to be raised in the demurrer. If an amended complaint, cross-complaint, or answer is filed, the responding party shall meet and confer again with the party who filed the amended pleading before filing a demurrer to the amended pleading.

 (1) As part of the meet and confer process, the demurring party shall identify all of the specific causes of action that it believes are subject to demurrer and identify with legal support the basis of the deficiencies. The party who filed the complaint, cross-complaint, or answer shall provide legal support for its position that the pleading is legally sufficient or, in the alternative, how the complaint, cross-complaint, or answer could be amended to cure any legal insufficiency.”

(Emphasis added).

 

            A similar provision applies to motions to strike. CCP § 435.5

 

The court views this obligation to meet and confer in good faith to extend to both sides in connection with a demurrer, as well as with a motion to strike. 

 

The court would be within its discretion to continue the motions and require the parties to meet and confer.  The court will instead require the parties to meet and confer by telephone prior to the matter being called for hearing and for plaintiff to prepare and submit by filing on eCourt the required meet and confer declaration under CCP § 430.41(a)(3) for review by the court prior to the motions being called for hearing.  

 

Substantive

Fourth Cause of Action—Inaccurate Wage Statements—Demurrer by Kim and Demurrer by Annavee, Inc. 

Statute of Limitations

            Defendants Kim and Annavee, Inc. have brought largely identical demurrers to plaintiff’s FAC.

 

Defendants first argue that the fourth cause of action for inaccurate wage statements fails to sufficiently allege a cause of action because the claim is barred by the applicable statute of limitations. 

 

            Defendants argue that the FAC makes clear that plaintiff’s employment with defendants ended on or around December 3, 2022.  [FAC, paras. 12-13].   The complaint in this case was filed on March 19, 2024.

 

Defendants argue that the applicable statute of limitations period with respect to wage statement penalties is one year, citing to CCP section 340(a), which provides, that the time for bringing an action is “Within one year,” for “(a) An action upon a statute for a penalty or forfeiture, if the action is given to an individual, or to an individual and the state, except if the statute imposing it prescribes a different limitation.”   The moving papers fail to cite the statute at issue, quote the statutory language, or indicate that the subject statute does not prescribe a different limitation.   

 

            The FAC brings the cause of action pursuant to Labor Code section 226, alleging that subdivision (e) mandates penalties.  The section provides, in pertinent part:

“(a) An employer, semimonthly or at the time of each payment of wages, shall furnish to their employee, either as a detachable part of the check, draft, or voucher paying the employee's wages, or separately if wages are paid by personal check or cash, an accurate itemized statement in writing showing (1) gross wages earned, (2) total hours worked by the employee, except as provided in subdivision (j), (3) the number of piece-rate units earned and any applicable piece rate if the employee is paid on a piece-rate basis, (4) all deductions, provided that all deductions made on written orders of the employee may be aggregated and shown as one item, (5) net wages earned, (6) the inclusive dates of the period for which the employee is paid, (7) the name of the employee and only the last four digits of their social security number or an employee identification number other than a social security number, (8) the name and address of the legal entity that is the employer and, if the employer is a farm labor contractor, as defined in subdivision (b) of Section 1682, the name and address of the legal entity that secured the services of the employer, and (9) all applicable hourly rates in effect during the pay period and the corresponding number of hours worked at each hourly rate by the employee and, beginning July 1, 2013, if the employer is a temporary services employer as defined in Section 201.3, the rate of pay and the total hours worked for each temporary services assignment. The deductions made from payment of wages shall be recorded in ink or other indelible form, properly dated, showing the month, day, and year, and a copy of the statement and the record of the deductions shall be kept on file by the employer for at least three years at the place of employment or at a central location within the State of California. For purposes of this subdivision, “copy” includes a duplicate of the itemized statement provided to an employee or a computer-generated record that accurately shows all of the information required by this subdivision….

 

(e)(1) An employee suffering injury as a result of a knowing and intentional failure by an employer to comply with subdivision (a) is entitled to recover the greater of all actual damages or fifty dollars ($50) for the initial pay period in which a violation occurs and one hundred dollars ($100) per employee for each violation in a subsequent pay period, not to exceed an aggregate penalty of four thousand dollars ($4,000), and is entitled to an award of costs and reasonable attorney's fees.

 

(2)(A) An employee is deemed to suffer injury for purposes of this subdivision if the employer fails to provide a wage statement….

 

(h) An employee may also bring an action for injunctive relief to ensure compliance with this section and is entitled to an award of costs and reasonable attorney's fees.”

 

            The statute expressly provides that an employee is deemed to suffer injury if there is a complete failure to provide a wage statement, presumably extending the date on which any limitations period would begin to run.

 

            The FAC here alleges:

“Defendants consistently withheld accurate, itemized wage statements from Plaintiff at each payment period, opting instead to provide generic earnings statements reflecting a fixed salary. These intentionally inaccurate statements misrepresented both gross and net earnings for Plaintiff and other employees.”

[FAC, para. 36].

 

The FAC alleges that Labor Code section 226(e) mandates penalties for employers who knowingly fail to provide an accurate, itemized wage statement, and that due to defendant’s conduct, plaintiff is entitled to those penalties.  [FAC paras. 37, 38].  

 

            The original complaint was filed on March 19, 2024.   The complaint alleges that plaintiff was forced to resign on December 3, 2022.  [FAC, para. 13].  It would appear from these allegations that plaintiff was receiving regular pay statements, which she alleges were inaccurate, and it would appear that those statements would have not extended past January of 2023, so that the complaint filed in March of 2024 was not filed within one year of the complained of misconduct.  

 

            The opposition does not address this argument but indicates “Plaintiff the Fourth and Thirteenth causes of action [sic] and thus Defendants’ Demurrer as to this cause of action is moot.”  It is not clear what plaintiff intends to state here.  First of all, there is no thirteenth cause of action in this action at all.  The statement evidently is intended to apply to the twelfth cause of action, as the demurrer to the fourth cause of action and the twelfth cause of action are not addressed on their merits in the opposition.

 

There is no request for dismissal of these causes of action, or any causes of action, in the file.  If plaintiff intends to withdraw those causes of action, plaintiff should have clearly so stated.  The court will construe plaintiff’s argument with respect to the fourth cause of action as a concession that the cause of action is insufficient.  Hence, the court sustains the demurrer to the cause of action without leave to amend. 

 

Fifth Cause of Action—Unfair Business Practices—Demurrer by Kim and Demurrer by Annavee, Inc. 

To state a cause of action for Unfair Business Practices, a plaintiff must allege the following elements:

1) Defendant has engaged in more than one unlawful, unfair, or fraudulent transaction, including unfair, deceptive, untrue or misleading advertising

2) Plaintiff’s right to restitution, if any.  Damages are not recoverable.

3) Plaintiff’s right to injunctive relief, if any.

Bus. & Prof. Code § 17200 et seq.; Dean Witter Reynolds, Inc. v. Superior Court (1989) 211 Cal.App.3d 758.

 

It is held that the Unfair Business Practices Act is not confined to anticompetitive business practices but is also directed toward the public’s right to protection for fraud, deceit, and unlawful conduct, and courts have thus “consistently interpreted the language of section 17200 broadly.”  Community Assisting Recovery, Inc. v. Aegis Security Ins. Co. (2001 2nd Dist.) 92 Cal.App.4th 886, 891, quoting South Bay Chevrolet v. General Motors Acceptance Corp. (1999) 72 Cal.App.4th 861, 877.  

 

Defendants argue that to the extent this cause of action is based on allegations that defendants unlawfully deducted tips, providing defendants with an unfair competitive advantage, plaintiff does not explain what she means by the allegations that defendants deducted tips, and does not allege that defendant retained any portion of any tips or gratuities for themselves, so it is not clear how defendant gains a competitive advantage. [See FAC, para. 41].   It does not appear that it is required that facts showing the gaining of an unfair competitive advantage must be alleged to satisfy the pleading elements.  

 

In any case, as pointed out in the opposition, the cause of action also alleges that defendants, “have engaged in unfair business practices in California by consistently failing to properly compensate employees. These violations include, but are not limited to, failure to pay overtime, inadequate provision of meal and rest periods, and non-compliance with Labor Code Sections 226 and 226.7.”  [FAC, para. 40].   The demurrer does not address these allegations, which involve alleged unlawful practices, in violation of statutory law.  

 

The demurrers are accordingly only addressed to part of the cause of action.  As plaintiff argues in the opposition, defendants improperly fail to take into account the entirety of plaintiff’s cause of action.  A demurrer does not lie to only part of a cause of action, and a cause will survive demurrer if there are sufficient allegations that might entitle the pleader to relief.  Kong v. City of Hawaiian Gardens Redevelop. Agency (2003, 2nd Dist.) 108 Cal.App.4th 1028, 1046; PH II, Inc. v. Superior Court (1995) 33 Cal.App.4th 1680, 1682.  The demurrers do not address the various other theories alleged to support unfair business practices cause of action. The motion to strike does not seek to strike these particular allegations from the pleading.  The demurrers accordingly are overruled to this cause of action.

 

Sixth Cause of Action—Violation of the Rule on Tips and Gratuities—Demurrer by Kim and Demurrer by Annavee, Inc. 

            Defendants argue that plaintiff’s sixth cause of action is based on Labor Code section 351, which provides no private right of action, so that plaintiff lacks capacity to sue under that statute.

 

            Labor Code section 351 provides:

“No employer or agent shall collect, take, or receive any gratuity or a part thereof that is paid, given to, or left for an employee by a patron, or deduct any amount from wages due an employee on account of a gratuity, or require an employee to credit the amount, or any part thereof, of a gratuity against and as a part of the wages due the employee from the employer. Every gratuity is hereby declared to be the sole property of the employee or employees to whom it was paid, given, or left for. An employer that permits patrons to pay gratuities by credit card shall pay the employees the full amount of the gratuity that the patron indicated on the credit card slip, without any deductions for any credit card payment processing fees or costs that may be charged to the employer by the credit card company. Payment of gratuities made by patrons using credit cards shall be made to the employees not later than the next regular payday following the date the patron authorized the credit card payment.”

 

Defendants rely on Lu v. Hawaiian Gardens Casino, Inc. (2010) 50 Cal.4th 592, in which the California Supreme Court expressly concluded that “section 351 does not contain a private right to sue.”  Lu, at 595. 

 

            The Court in Lu reviewed the statutory language, the penalties provided in the statutory scheme, including that the employer is guilty of a “misdemeanor,” and is subject to a fine or imprisonment, and the identification in the statutory scheme of an agency charged with enforcing the tipping practices provisions, and also reviewed the legislative history of Labor Code section 351 and related provisions, and concluded that “there is no clear indication that the Legislature intended to create a private cause of action under the statute.”  Lu, at 600. 

 

The Court in Lu noted that employees were not completely without remedy where an employer fails to properly pay gratuities but could bring a claim against the employer not based on Labor Code section 351, such as pursuant to a cause of action for conversion.  Lu, at 603-604. 

The Court noted that the statute expressly provides that “Every gratuity is hereby declared to be the sole property of the employee or employees to whom it was paid, given, or left for,” which language, “suggests that employees may bring an action to recover any misappropriated tips to which they are entitled, just as with other property rights.”  Lu, at 598.  The Court cited to CCP section 28, which provides, “An injury to property consists in depriving its owner of the benefit of it.” Lu, at 598. 

The Court more specifically noted:

“Contrary to plaintiff's suggestion, our holding that section 351 does not provide a private cause of action does not necessarily foreclose the availability of other remedies. To the extent that an employee may be entitled to certain misappropriated gratuities, we see no apparent reason why other remedies, such as a common law action for conversion, may not be available under appropriate circumstances. (See Moradi–Shalal, supra, 46 Cal.3d at pp. 304–305, 250 Cal.Rptr. 116, 758 P.2d 58 [even without private cause of action under statute, “courts retain jurisdiction to impose civil damages or other remedies ... in appropriate common law actions”]; see also Civ.Code, § 3523 [“For every wrong there is a remedy”].)”

Lu, at 603-604, footnote omitted.

 

            Plaintiff in opposition argues that there is case law that supports a private right of action against employers who unlawfully withhold gratuities.  Plaintiff cites to Grodensky v. Artichoke Joe’s Casino (2009) 171 Cal.App.4th 1399, which was decided by the First District Court of Appeal before the issuance of the decision in Lu.  Plaintiff fails to point out to this court that in connection with the Grodensky case, on June 24, 2009, the California Supreme Court granted a petition for review, and expressly held that further action in the matter was “deferred pending consideration and disposition of a related issue” in Lu. See Grodensky v. Artichoke Joe’s Casino (2009) 211 P.3d 1061.   This argument appears intended to mislead this court concerning the state of the law.

 

In any case, a more recent California Supreme Court case cited in the moving papers, Kim v. Reins International California, Inc. (2020) 9 Cal.5th 73, has expressly recognized, citing Lu, that Labor Code section 351 is among the “numerous” Labor Code statutes which “impose civil penalties without affording a private right of action.”  Kim, at 89 (“Lu v. Hawaiian Gardens Casino, Inc. (2010) 50 Cal.4th 592, 601, 113 Cal.Rptr.3d 498, 236 P.3d 346, for example, held there is no private right of action under section 351, which prohibits employers from taking employees’ tips.”) 

 

This court accordingly finds that plaintiff here has failed to establish the existence of a private right of action under Labor Code section 351. 

 

            Plaintiff also argues that if the court should find that section 351 is only available to the Labor Commissioner, plaintiff can amend the cause of action to assert claims based on conversion, or other applicable common law or statutory theories.  This approach is what the Court appeared to suggest would be appropriate in Lu. 

 

The demurrers accordingly are sustained to the cause of action as based on Labor Code section 351, but with leave to amend to state a claim based on the alleged failure to properly pay gratuities under some other legal theory, if possible.  

 

Twelfth Cause of Action—Violation of Labor Code 1174.5—Demurrer by Kim and Demurrer by Annavee, Inc.

Defendants argue that plaintiff’s twelfth cause of action, premised on an alleged violation of Labor Code section 1174.5, also fails as there is no private right of action to enforce that section of the Labor Code. 

 

Labor Code section 1174.5 provides:

“Any person employing labor who willfully fails to maintain the records required by subdivision (c) of Section 1174 or accurate and complete records required by subdivision (d) of Section 1174, or to allow any member of the commission or employees of the division to inspect records pursuant to subdivision (b) of Section 1174, shall be subject to a civil penalty of five hundred dollars ($500).”

 

Defendants argue that the only remedy for a violation of Labor Code § 1174.5 is a civil penalty in the amount of $500, which is recoverable by the Labor Commissioner.

 

Defendants cite to Kim v. Reins International California, Inc. (2020) 9 Cal.5th 73, in which the California Supreme Court addressed the issue of whether employees lose standing to pursue a claim under the Labor Code Private Attorney General Act (PAGA, Labor Code section 2698 et seq.) if they settle and dismiss their individual claims for Labor Code violations, and determined that the employees do not lose standing to pursue PAGA remedies. 

 

Defendants rely on a discussion in that case which does not mention Labor Code section 1174.5, but which observes that “numerous” Labor Code statutes “impose civil penalties without affording a private right of action,” including Labor Code sections 351 (citing Lu, as discussed above), 226.8, and 558.   

 

Defendants rely on the discussion in Kim in which the Court observes:

“ ‘[W]hen regulatory statutes provide a comprehensive scheme for enforcement by an administrative agency,’ ” as with the Labor Code, “ ‘courts ordinarily conclude that the Legislature intended the administrative remedy to be exclusive unless the statutory language or legislative history clearly indicates an intent to create a private right of action.’ ” (Thurman v. Bayshore Transit Management, Inc. (2012) 203 Cal.App.4th 1112, 1132, 138 Cal.Rptr.3d 130, disapproved on another ground in ZB, N.A. v. Superior Court, supra, 8 Cal.5th at p. 196, fn. 8, 252 Cal.Rptr.3d 228, 448 P.3d 239.)

Kim, at 89.

 

            Defendants then argue that there is no statutory language or legislative history that suggests the legislature intended to create a private right of action to enforce Labor Code section 1174.5.

 

            Plaintiff in opposition does not address this argument on its merits, but indicates, as noted above, that “Plaintiff the Fourth and Thirteenth causes of action [sic] and thus Defendants’ Demurrer as to this cause of action is moot.”  Again, it is not clear what plaintiff intends, and there has been no formal request to dismiss any portion of the FAC. 

 

In light of the fact that there is no thirteenth cause of action in the operative complaint, the demurrer is to the twelfth cause of action, and the demurrer to that cause of action is not opposed on its merits, the court construes the opposition papers as conceding that the twelfth cause of action is insufficient.  Hence, the court sustains the demurrer to the cause of action without leave to amend.

 

Motion to StrikeMotion by Annavee, Inc.

            The motion to strike is brought only by the corporate defendant, Annavee, Inc., which argues that the FAC improperly seeks punitive damages, and penalties and relief pursuant to Labor Code section 2699.

 

Under CCP § 435, a party may serve and file a motion to strike a part of a pleading. 

 

Under CCP § 436:

“The court may, upon a motion made pursuant to CCP § 435, or at any time in its discretion, and upon terms it deems proper:

(a) Strike out any irrelevant, false, or improper matter inserted in any pleading.

(b) Strike out all or any part of any pleading not drawn or filed in conformity with the laws of this state, a court rule, or an order of the court.”

 

Under CCP § 431.10(c), an “immaterial allegation,” as defined in that section, “means ‘irrelevant matter’ as that term is used in Section 436.”

 

CCP § 431.10(b) defines an immaterial allegation as follows:

“(b) An immaterial allegation in a pleading is any of the following:

(1) An allegation that is not essential to the statement of a claim or defense.

(2) An allegation that is neither pertinent to nor supported by an otherwise sufficient claim or defense.

(3) A demand for judgment requesting relief not supported by the allegations of the complaint or cross-complaint.” 

 

For purposes of ruling on a motion to strike, the allegations of the pleading are assumed to be true.  Clauson v. Superior Court (1998 2nd Dist.) 67 Cal.App.4th 1253, 1255. 

 

Punitive Damages

Civil Code § 3294 authorizes recovery of punitive damages “in an action for breach of an obligation not arising from contract…” on the basis of findings that “the defendant has been guilty of oppression, fraud or malice.”

 

The motion first argues that punitive damages may not be awarded based on a cause of action for failure to pay overtime wages.   Defendant argues that punitive damages sought in connection with the first cause of action is therefore improper. 

 

The first cause of action alleges that plaintiff often worked more than eight hours per day or forty hours per week, but defendants failed to provide plaintiff with appropriate overtime compensation.  [FAC, para. 19].  The cause of action alleges that this is in violation of certain Labor Code sections and that as a result of defendants’ unlawful practices, “Plaintiff suffered financial losses, including diminished earnings for overtime hours worked.”  Plaintiff accordingly “seeks recovery for interest, attorneys’ fees, costs, and an injunction mandating Defendants’ compliance with overtime pay regulations.”  [FAC, para. 23].  There is no request in the cause of action for punitive damages which the court may strike.  Punitive damages are sought generally in the prayer, which seeks, “exemplary and punitive damages in an amount to be determined by the Court.”  [FAC, Prayer, para. D].   The prayer is directed to “all causes of action,” but the motion to strike is directed only to the first cause of action for failure to pay overtime and ninth cause of action for constructive wrongful termination and retaliation, so defendants have failed to show that the punitive damages are not stated properly as to at least one of the numerous causes of action. 

 

In any case, punitive damages are not sought directly in the first cause of action.  At best, the cause of action alleges that defendants’ conduct was deliberate, carried out in bad faith, and demonstrates “malicious intent.”  [FAC, para. 24].  This allegation must be taken as true for purposes of a motion to strike, and it appears that this allegation, unaccompanied by a direct claim for punitive damages, cannot be appropriately stricken from the pleading.  The overall claim for punitive damages cannot be stricken in light of its application to all causes of action.  The motion to strike on this ground accordingly is denied. 

 

However, plaintiff has failed to file timely opposition to the motion to strike.  The court at the hearing will hear oral argument with respect to whether on amendment, plaintiff would like leave to eliminate the allegations of malicious intent from the first cause of action.  

 

Defendant also argues that punitive damages are improperly sought in connection with plaintiff’s ninth cause of action for constructive wrongful termination and retaliation in violation of public policy. 

 

The cause of action itself alleges that defendants’ conduct justifies “punitive damages to deter similar behavior in the future.”  [FAC, para. 62]. 

 

The cause of action alleges that defendants engaged in discriminatory practices and retaliatory actions, and that defendants’ retaliation against plaintiff for speaking out against discrimination and unfair labor practices is a direct violation of public policy, disregards labor laws and undermines basic principles of fairness and equity.   [FAC, paras. 56-60]. 

    

            The motion to strike concedes that it would be possible to obtain an award of punitive damages on a wrongful termination or retaliation claim.   Defendant argues, however, that plaintiff fails to plead facts sufficient to support an award of punitive damages, as the allegations of the FAC related to retaliation are that when plaintiff raised concerns about age-based discrimination, defendants responded by further cutting her hours, ultimately forcing her to resign, without any details concerning the content of any alleged complaint, to whom it was made, in what form, or the date on which it was communicated, and without specifying the extent to which plaintiff’s hours were allegedly cut.  There is no legal authority cited under which this level of detail is a pleading requirement for seeking punitive damages in an age discrimination/retaliation claim.  Hence, this approach appears to be more in the nature of a demurrer to the sufficiency of the cause of action, not a motion to strike a claim for punitive damages where age discrimination and retaliation are at issue.  The motion to strike on this ground is denied.

 

            The motion also argues that the FAC fails to plead fact sufficient to support an award of punitive damages against Annavee, Inc., a corporate defendant, because there are insufficient allegations that the act of oppression, fraud or malice was on the part of an officer, director, or managing agent of defendant.

 

Civil Code § 3294(b) requires that a plaintiff seeking punitive damages against a corporation must show such wrongful conduct by managing personnel of the corporation:

“An employer shall not be liable for [exemplary]...damages based upon acts of an employee of the employer, unless the employer...ratified the wrongful conduct for which the damages are awarded or was personally guilty of oppression, fraud or malice.  With respect to a corporate employer, the advance knowledge and conscious disregard, authorization, or ratification of an act of oppression, fraud or malice must be on the part of an officer, director or managing agent of the corporation. “

 Civil Code § 3294(b). 

 

The FAC includes general allegations concerning the conduct of defendant Kim as a managing agent of the corporate defendant:

“Plaintiff asserts that KIM should be held accountable for specific labor violations given her roles in ownership, operations, and/or management within CHANG’S GARDEN. In her capacity as an owner, director, officer, or managing agent of CHANG’S GARDEN, KIM is implicated in breaches of minimum wage regulations, hours of work provisions set by the Industrial Welfare Commission, and violations of Labor Code Sections § 510, § 226, § 226.7, § 512, § 558, § 1174, and § 1198.”

[FAC, para. 16]. 

 

It is also alleged that:

“68. Defendant KIM, in her capacity as an owner, director, officer, or managing agent, had direct control and authority over the operations and management of CHANG’S GARDEN, including but not limited to employment practices, wage policies, and compliance with labor laws.

 

69. Despite being aware or having the obligation to be aware of the labor violations occurring at CHANG’S GARDEN, Defendant KIM failed to take appropriate corrective actions to ensure compliance with the provisions of the Labor Code.

 

70. As a result of Defendant KIM’s neglect or active participation in the labor violations, Plaintiff and other employees suffered financial harm, emotional distress, and infringement of their statutory rights under the Labor Code. Plaintiff asserts that KIM should be held accountable for specific labor violations given her roles in ownership, operations, and/or management within CHANG’S GARDEN. In her capacity as an owner, director, officer, or managing agent of CHANG’S GARDEN, KIM is implicated in breaches of minimum wage regulations, hours of work provisions set by the Industrial Welfare Commission, and violations of Labor Code Sections § 510, § 226, § 226.7, § 512, § 558, § 1174, and § 1198C.”

[FAC paras. 68-70].

 

There is authority under which allegations may be sufficient where they involve a director, officer, or managing agent who exercises substantial discretionary authority over significant aspects of a corporation’s business and policy.  See CRST, Inc. v. Superior Court (2017, 2nd Dist.) 11 Cal.App. 5th 1255, 1273, citing White v. Ultramar, Inc. (1999) 21 Cal.4th 563, 576-577.  This situation appears what to be alleged here, as the FAC refers to Annavee, Inc.’s officer, director or manager engaging in the conduct of adopting or ratifying policies which implicate violation of public policy, such as discriminatory practices.

 

The motion to strike on this ground accordingly is denied.  

 

            The motion also appears to briefly argue that the FAC does not allege any conduct on the part of defendant Annavee Kim at all.   The motion to strike is not brought by defendant Kim, but only by defendant Annavee, Inc.  There is no separate motion to strike brought by Kim.  In addition, as quoted above, there are sufficient allegations of Kim’s participation in wrongful conduct here in her position as an owner, operator, and manager of Chang’s Garden.  The motion to strike is denied on this ground.   

 

Penalties—Labor Code Section 2699

            Defendant argues that the court should strike the prayer for damages which seeks penalties pursuant to Labor Code section 2699, because that section pertains to PAGA claims, when there is no PAGA claim being asserted in the FAC.  

 

            The FAC seeks in the prayer, “Penalties and relief pursuant to Labor Code section 2699.”  [FAC, Prayer, para. J].

 

            Labor Code section 2699 provides, in pertinent part:

“(a) Notwithstanding any other provision of law, any provision of this code that provides for a civil penalty to be assessed and collected by the Labor and Workforce Development Agency or any of its departments, divisions, commissions, boards, agencies, or employees, for a violation of this code, may, as an alternative, be recovered through a civil action brought by an aggrieved employee on behalf of the employee and other current or former employees against whom a violation of the same provision was committed pursuant to the procedures specified in Section 2699.3.”

 

            The complaint here does not include a cause of action brought by plaintiff on behalf of herself and other current or former employees pursuant to the provisions specified in Section 2699.3, which requires, among other things, that the aggrieved employee give written notice to the employer through various agencies, and pay special filing fees, none of which is alleged to have been done here. 

 

            The prayer appears to have been included in error.  The opposition papers do not address this argument, or request that leave to amend include leave to assert a new cause of action under Labor Code section 2699.  The motion to strike is granted without leave to amend.

 

RULING:

Demurrer to Plaintiff’s First Amended Complaint by Defendant Annavee Wingyi Wong Kim:

The Court notes that the meet and confer declaration submitted with the demurrers and motion to strike indicates that plaintiff’s counsel failed to respond to meet and confer efforts, including two written correspondences.   The Court views the obligation to meet and confer to extend to both plaintiff and defendants.  See CCP § 430.41(a)(1) (“The party who filed the complaint, cross-complaint, or answer shall provide legal support for its position that the pleading is legally sufficient or, in the alternative, how the complaint, cross-complaint, or answer could be amended to cure any legal insufficiency.”).  See also CCP § 435.5, applying to motions to strike. 

The parties are ordered to meet and confer in good faith by telephone prior to the hearing on the demurrer, and plaintiff’s counsel is ordered to efile with the Court the required declaration indicating the outcome of those efforts, and clearly indicating which issues remain for the Court to resolve on the demurrer of defendant Kim.  The Court will not hear the demurrer, and plaintiff will not be assigned a trial date, until plaintiff has appropriately met and conferred on the status of the pleadings.

 

Demurrer is to the fourth cause of action for inaccurate wage statements is SUSTAINED WITHOUT LEAVE TO AMEND, based on the apparent concession in the opposition that the cause of action is withdrawn, and the lack of substantive opposition to the motion, on the ground the cause of action is barred by the applicable statute of limitations.     

 

Demurrer to the fifth cause of action for unfair business practices is OVERRULED.  The demurrer is addressed only to the allegations that defendants unlawfully deducted tips but does not address or challenge the allegations that defendants engaged in unfair business practices by failing to properly compensate employees under numerous unrelated specified Labor Code sections. [FAC, para. 40].  Because a demurrer does not lie to only part of a cause of action, and a cause will survive demurrer if there are sufficient allegations that might entitle the pleader to relief, the demurrer is overruled.  Kong v. City of Hawaiian Gardens Redevelop. Agency (2003, 2nd Dist.) 108 Cal.App.4th 1028, 1046; PH II, Inc. v. Superior Court (1995) 33 Cal.App.4th 1680, 1682.  

 

Demurrer to the sixth cause of action for violation of the rule on tips and gratuities is SUSTAINED WITH LEAVE TO AMEND on the ground the cause of action is based on Labor Code § 351, and the California Supreme Court has held that there is no private right of action to enforce Labor Code § 351. Lu v. Hawaiian Gardens Casino, Inc. (2010) 50 Cal.4th 592, 595, 600.  The demurrer is sustained with leave to amend to permit plaintiff to amend the pleading, if possible, to seek recovery of the alleged withheld tips on some other viable.  See Lu, at 598, 603-604. 

 

Demurrer to the twelfth cause of action for violation of Labor Code 1174.5 is SUSTAINED WITHOUT LEAVE TO AMEND, based on the apparent concession in the opposition that the cause of action is withdrawn, and the lack of substantive opposition to the motion, on the ground the cause of action is based on a statute which does not provide a private right of action. 

 

Ten days leave to amend the sixth cause of action only, if possible. 

 

 

Demurrer to Plaintiff’s First Amended Complaint by Defendant Annavee, Inc.:

The Court notes that the meet and confer declaration submitted with the demurrers and motion to strike indicates that plaintiff’s counsel failed to respond to meet and confer efforts, including two written correspondences.   The Court views the obligation to meet and confer to extend to both plaintiff and defendants.  See CCP § 430.41(a)(1) (“The party who filed the complaint, cross-complaint, or answer shall provide legal support for its position that the pleading is legally sufficient or, in the alternative, how the complaint, cross-complaint, or answer could be amended to cure any legal insufficiency.”).  See also CCP § 435.5, applying to motions to strike. 

The parties are ordered to meet and confer in good faith by telephone prior to the hearing on the demurrer and motion to strike, and plaintiff’s counsel is ordered to efile with the Court the required declaration indicating the outcome of those efforts, and clearly indicating which issues remain for the Court to resolve on the demurrers and motion to strike.  The Court will not hear the demurrers or motion to strike, and plaintiff will not be assigned a trial date, until plaintiff has appropriately met and conferred on the status of the pleadings.

 

Demurrer is to the fourth cause of action for inaccurate wage statements is SUSTAINED WITHOUT LEAVE TO AMEND, based on the apparent concession in the opposition that the cause of action is withdrawn, and the lack of substantive opposition to the motion, on the ground the cause of action is barred by the applicable statute of limitations.    

 

Demurrer to the fifth cause of action for unfair business practices is OVERRULED.  The demurrer is addressed only to the allegations that defendants unlawfully deducted tips but does not address or challenge the allegations that defendants engaged in unfair business practices by failing to properly compensate employees under numerous unrelated specified Labor Code sections. [FAC, para. 40].  Because a demurrer does not lie to only part of a cause of action, and a cause will survive demurrer if there are sufficient allegations that might entitle the pleader to relief, the demurrer is overruled.  Kong v. City of Hawaiian Gardens Redevelop. Agency (2003, 2nd Dist.) 108 Cal.App.4th 1028, 1046; PH II, Inc. v. Superior Court (1995) 33 Cal.App.4th 1680, 1682.  

 

Demurrer to the sixth cause of action for violation of the rule on tips and gratuities is SUSTAINED WITH LEAVE TO AMEND on the ground the cause of action is based on Labor Code § 351, and the California Supreme Court has held that there is no private right of action to enforce Labor Code § 351. Lu v. Hawaiian Gardens Casino, Inc. (2010) 50 Cal.4th 592, 595, 600.  The demurrer is sustained with leave to amend to permit plaintiff to amend the pleading, if possible, to seek recovery of the alleged withheld tips on some other viable theory.  See Lu, at 598, 603-604. 

 

Demurrer to the twelfth cause of action for violation of Labor Code 1174.5 is SUSTAINED WITHOUT LEAVE TO AMEND, based on the apparent concession in the opposition that the cause of action is withdrawn, and the lack of substantive opposition to the motion, on the ground the cause of action is based on a statute which does not provide a private right of action. 

 

Ten days leave to amend the sixth cause of action only, if possible. 

 

Defendant Annavee, Inc.’s Motion to Strike Portions of Plaintiff’s First Amended Complaint:

Motion to strike allegations and prayer for punitive damages is DENIED.

Motion to strike prayer for penalties and relief pursuant to Labor Code section 2699 is GRANTED WITH LEAVE TO AMEND.  Plaintiff is permitted leave to amend to allege a claim for relief under Labor Code section 2699, if plaintiff had intended to do so, and if possible, given the requirements of Labor Code section 2699.3.  Otherwise, the motion is GRANTED WITHOUT LEAVE TO AMEND

 

Ten days leave to amend only to state a claim under Labor Code section 2699, if possible. 

 

The parties are ordered to meet and confer in full compliance with CCP §§ 430.41 and 435.5 before any further demurrer or motion to strike may be filed.  

 

 

 DEPARTMENT D IS CONTINUING TO CONDUCT AND ENCOURAGE

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