Judge: Sarah J. Heidel, Case: 23BBCV02683, Date: 2024-05-03 Tentative Ruling



Case Number: 23BBCV02683    Hearing Date: May 3, 2024    Dept: V


 

SUPERIOR COURT OF CALIFORNIA

COUNTY OF LOS ANGELES – NORTHEAST DISTRICT

DEPARTMENT V

 

LEXHAM OLIVE, LLC, A DELAWARE LIMITED LIAIBLITY COMPANY,

Plaintiff,

vs.

THE CARVING BOARD, LLC, A CALIFORNIA LIMITED LIABILITY COMPANY; WESCO INSURANCE COMPANY; RDCS SERVICE INC. DBA LJ CONSTRUCTION; DOE CONTRACTOR INSURANCE COMPANY; and DOES 1 through 20, inclusive, Defendants.

Case No.: 23BBCV02683

 Hearing Date: May 3, 2024

Time: 9:00 a.m.

[TENTATIVE] ORDER RE: DEMURRER OF DEFENDANT WESCO INSURANCE COMPANY TO LEXHAM OLIVE, LLC’S COMPLAINT

 

MOVING PARTIES:

Defendant WESCO INSURANCE COMPANY

RESPONDING PARTY: Plaintiff LEXHAM OLIVE, LLC

The court considered the moving papers, opposition and reply.

BACKGROUND

Plaintiff leased commercial space to defendant The Carving Board, LLC (TCB). Plaintiff alleges that it suffered damages resulting from faulty work performed by TCB’s contractor RDCS SERVICES INC. DBA LJ CONSTRUCTION (RDCS). The Complaint alleges the causes of action for (1) negligence (against The Carving Board and RDCS Services Inc., (2) breach of written contract (against The Carving Board), (3) breach of insurance contract (against Wesco  Insurance Company (Tenant/Landlord Insurer)), (4) breach of contract (against RDCS Service Inc. and Doe Contractor Insurance Company), and (5) fraud (against The Carving Board).

Defendant Wesco Insurance Company filed the demurrer on February 7, 2024. Plaintiff opposes.

LEGAL STANDARD

A party may object to a complaint or cross-complaint the party may file a demurrer, an answer, or both. (Code of Civ. Proc., § 430.30.) The demurrer may be filed within 30 days after service of the complaint or cross-complaint unless extended by stipulation or court order. (Code of Civ. Proc. § 430.40(a).)

As a general matter, 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 pleading alone, and not the evidence or facts alleged.” (E-Fab, Inc. v. Accountants, Inc. Servs. (2007) 153 Cal.App.4th 1308, 1315.) As such, the court assumes the truth of the complaint’s properly pleaded or implied factual allegations. (Id.) The only issue a demurrer is concerned with is whether the complaint, as it stands, states a cause of action. (Hahn v. Mirda (2007) 147 Cal.App.4th 740, 747.)

 

DISCUSSION

Defendant Wesco Insurance Company demurs to the third cause of action for breach of insurance contract on the grounds that plaintiff failed to state facts sufficient to constitute a cause of action against defendant.      

Timeliness

Plaintiffs served the summons and complaint on December 8, 2023. Under Code of Civil Procedure section 430.40, Wesco had 30 days from the date of service, in other words until January 8, 2024, to file the demurrer by. Because Wesco filed on February 7, 2024, the demurrer is apparently untimely. The court will nevertheless exercise its discretion and address the merits. (Jackson v. Doe (2011) 192 Cal.App.4th 742, 750.)

A.      Meet and Confer


The parties must meet and confer in person, by telephone, or by video conference prior to any party filing a demurrer. (Code Civ. Proc., § 430.41(a).) Here, the parties exchanged letters, which is technically insufficient. However, failure to sufficiently meet and confer is not a basis upon which the court may overrules or sustains the demurrer. (Code of Civ. Proc., § 430.41(a)(4).) Therefore, the court will discuss the merits of the demurrer.    

 
Plaintiff has sufficiently alleged that it is an insured of the defendant’s policy.

Defendant argues that plaintiff is a “beneficiary” of the insurance policy and not an insured and is therefore cannot directly sue the Wesco until it has obtained a judgment against the insured.

In its complaint, Plaintiff attached a certificate of liability insurance stating that Lexham Olice, LLC is “included as additional insured with respect to the premises rented or leased by the named insured.” (Complaint, Exh. C.) The attached certificate of liability insurance also defines an insured to include “any person or organization with whom you [the named insured, The Carving Board] agreed, because of written contract or written agreement to provide insurance but only with respect to. . . “property damage” arising out of “your products” which are distributed or sold in the regular course of the vendors business. . .” (Complaint, Exh. C.) The allegations are sufficient to alleges that Plaintiff is an insured under the policy.

C.     Plaintiff failed to allege the material terms of the Wesco Insurance Policy

To plead a breach of written contract cause of action, the terms must be set out verbatim in the body of the complaint or a copy of the written instrument must be attached and incorporated by reference. (Holly Sugar Corp v. McColgan (1941) 18 Cal.2d 218, 225.)

 The complaint did not include the terms of the insurance policy nor was a copy of the insurance policy attached. Plaintiff appears to concede this point but argues that defendant has improperly failed to provide it with a copy of the policy. That argument does not address the deficiency in the pleadings.

D.     Plaintiff failed to properly allege a bad faith breach of contract claim.

In order to plead a bad-faith breach of contract cause of action, plaintiff must plead that (1) there is a contractual relationship between the parties, (2) the benefits are due under the terms of the policy, and (3) the insurance company’s withholding of benefits is unreasonable.

i.                    Contractual relationship

Defendant argues that the plaintiff’s only allegation is based on information and belief that The Cutting Board purchased insurance for the benefit of the plaintiff. Here, the plaintiff has provided sufficient factual allegations that a contractual relationship exists between the plaintiff and defendant because Lexham Olive, LLC is listed as an additional insured with respects to the premises rented by the named insured, The Carving Board, LLC on the certificate of liability insurance as discussed above. (Complaint, Exh. C.

ii.                   Benefits under the terms of the policy

Defendant argues that the complaint failed to include fundamental allegations that benefits are due under the terms of the policy. Plaintiff did not address whether their claim fell under the terms of the policy because the plaintiff did not include the terms of the policy either in the complaint. Here, the plaintiff did not provide sufficient factual allegations to show the claim they submitted fell under the terms of the policy.

iii.                 Reasonableness of withholding

Defendant argues that the complaint failed to allege that the denial of the claim was unreasonable. The complaint states that defendant breached the policy by denying the claim, failing to pay the claim, failing to investigate the claim, and failing to provide reasons for the denial. (Complaint ¶ 34). Plaintiff attaches to the complaint the denial letter from the insurer and alleges that the denial was in bad faith. The court agrees that the complaint does not sufficiently allege that the withholding of the benefits sought by plaintiff was unreasonable. Among other things, the letter attached to the complaint tends to show that Wesco did investigate, in that it “advise[s] that our investigation has determined that there is no coverage available for this loss under our insured’s policy.” (Complaint, Exh. D). And the bare allegation that the denial letter failed to provide reasons for the denial is not enough to establish bad faith.  

E.      The No-Action Clause

Defendant also argues the policy at issue has a “no-action” clause that bars the plaintiff from suing defendant, the insurer, because plaintiff is suing the named insured, The Carving Board, in the same action. Defendant argues that the no-action clause would apply because plaintiff is not the insured. The policy is not attached as part of the pleadings and the court will not address this argument, which is speculative at this time.

Based on the foregoing, the court SUSTAINS the demurrer with 20 days leave to amend