Judge: Serena R. Murillo, Case: 19STCV07180, Date: 2022-09-27 Tentative Ruling
Case Number: 19STCV07180 Hearing Date: September 27, 2022 Dept: 29
Edward
Hurtado, et al. v. Numbers One Liftgate and Trailer Repair Corp., et al.
Motion for Terminating Sanctions for Failure to Respond to Court Order
filed by Defendant
Mercury Insurance Group on behalf of Number One Liftgate and Trailer Repair
Corp ![]()
TENTATIVE
Defendant Mercury
Insurance Group on behalf of Number One Liftgate and Trailer Repair Corp’s
motion for terminating sanctions dismissing Plaintiff Jennifer Godoy’s
complaint against Defendants is GRANTED. The Court dismisses Plaintiff Godoy’s
complaint against Defendants Number One Liftgate and Trailer Repair Corp. with prejudice.
Legal
Standard
CCP section
2023.030 provides that, "[t]o the extent authorized by the chapter
governing any particular discovery method..., the court, after notice to any
affected party, person, or attorney, and after opportunity for hearing, may
impose... [monetary, evidence, and terminating] sanctions against anyone
engaging in conduct that is a misuse of the discovery process...." CCP
section 2023.010 provides that "[m]issues of the discovery process
include, but are not limited to, the following:... (d) Failing to respond or to
submit to an authorized method of discovery.... (g) Disobeying a court order to
provide discovery...."
"The trial
court may order a terminating sanction for discovery abuse 'after considering
the totality of the circumstances: [the] conduct of the party to determine if
the actions were willful; the detriment to the propounding party; and the
number of formal and informal attempts to obtain the discovery.'" (Los
Defensores, Inc. v. Gomez (2014) 223 Cal.App.4th 377, 390 (quoting Lang
v. Hachman (2000) 77 Cal.App.4th 1225, 1246).) "Generally, '[a]
decision to order terminating sanctions should not be made lightly. But where a
violation is willful, preceded by a history of abuse, and the evidence shows
that less severe sanctions would not produce compliance with the discovery
rules, the trial court is justified in imposing the ultimate sanction.'" (Los
Defensores, supra, 223 Cal.App.4th at p. 390 (citation omitted).)
"Under this
standard, trial courts have properly imposed terminating sanctions when parties
have willfully disobeyed one or more discovery orders." (Id. (citing Lang,
supra, 77 Cal.App.4th at pp. 1244- 1246); see, e.g., Collisson X Kaplan v.
Hartunian (1994) 21 Cal.App.4th 1611, 1617-1622 (terminating sanctions
imposed after defendants failed to comply with one court order to produce
discovery); Laguna Auto Body v. Farmers Ins. Exchange (1991) 231 Cal App
3d 481, 491 (disapproved on other grounds in Garcia v. McCucchen (1997)
16 Cal.4th 469, 478, n. 4) (terminating sanctions imposed against plaintiff for
failing to comply with a discovery order and for violating various discovery
statutes).)
Discussion
Defendant moves
for terminating sanctions against Plaintiff Jennifer Godoy on the ground that
Plaintiff failed to comply with the Court's June 14, 2022 order compelling her
to respond to discovery and pay monetary sanctions.
On June
14, 2022, this Court granted Defendant’s Motions to Compel and ordered
Plaintiff Godoy to serve verified responses to Form Interrogatories, Special
Interrogatories, and Request for Production of Documents within 30 days, and to
pay sanctions in the amount of $560 within 30 days of the order. (6/14/2022
Minute Order.) Defendant served notice of the Court’s June 14, 2022 Order on
June 16, 2022. (Desalernos Decl., Exh. A.) Despite the Court’s June 14, 2022
Order, Plaintiff failed to respond to discovery or pay sanctions. (Id., ¶ 5.)
The Court finds
terminating sanctions action against Plaintiff Godoy is appropriate. Plaintiff
has failed to respond to discovery, failed to comply with the Court's order to
respond to discovery, failed to oppose
this motion for terminating sanctions,
and failed to pay monetary sanctions imposed against Plaintiff. Thus, it
appears imposing less severe sanctions against Plaintiff would not produce
compliance, and that Plaintiff is disinterested in prosecuting this case.
Conclusion
Based on the
foregoing, Defendant’s motion for terminating sanctions dismissing Plaintiff
Jennifer Godoy’s complaint against Defendants is GRANTED. The Court dismisses
Plaintiff Godoy’s complaint against Defendants Number One Liftgate and Trailer
Repair Corp. with prejudice.
Moving party is
ordered to give notice.