Judge: Serena R. Murillo, Case: 19STCV13516, Date: 2023-01-13 Tentative Ruling

DEPARTMENT 29 - LAW AND MOTION RULINGS IMPORTANT  (PLEASE SEND YOUR E-MAIL TO DEPT. 29 NOT DEPT. 2)

Communicating with the Court Staff re the Tentative Ruling 1. Please notify the courtroom staff by email not later than 9:30 a.m. on the day of the hearing if you wish to submit on the tentative ruling rather than argue the motion. The email address is SSCDEPT29@lacourt.org. Please do not use any other email address. 2. You must include the other parties on the email by "cc." 3. Include the word "SUBMISSION" in all caps in the Subject line and include your name, contact information, the case number, and the party you represent in the body of the email. If you submit on the tentative and elect not to appear at the hearing, the opposing party may nevertheless appear at the hearing and argue the motions. THE COURT WILL HEAR ARGUMENT UNLESS BOTH SIDES SUBMIT ON THE TENTATIVE.  4. Include the words "SUBMISSION BUT WILL APPEAR" if you submit, but one or both parties will nevertheless appear. 5. For other communications with Court Staff a. OFF-CALENDAR should appear in all caps in the Subject line where all parties have agreed to have a matter placed off-calendar. All counsel should be cc'ed (and where appropriate parties not represented by counsel) and the body of the email should state: (a) name and case number; (b) date of proceeding. b. CASE SETTLED should appear in all caps in the Subject line where all parties have agreed that the case has settled for all purposes. All counsel should be cc'ed (and where appropriate parties not represented by counsel) and the body of the email should state: (a) name and case number; (b) whether notice of settlement/dismissal documents have been filed; (c) if (b) has not been done, a date one year from the date of your email which will be a date set by the court for an OSC for dismissal of the case. c. STIPULATION should appear in all caps in the Subject line where all parties have stipulated that a matter before the court can be postponed. All counsel should be cc'ed (and where appropriate parties not represented by counsel) and the body of the email should state: (a) name and case number; (b) what proceeding is agreed to be postponed e.g. Trial, FSC; (c) the agreed-upon future date; (d) whether all parties waive notice if the Court informs all counsel/parties that the agreed-upon date is satisfactory. This communication should be used only for matters that are agreed to be postponed and not for orders shortening time. 6. PLEASE MAKE SURE THAT ALL COMMUNICATIONS WITH COURT STAFF DEAL ONLY WITH SCHEDULING AND ADMINISTRATIVE MATTERS AND DO NOT DISCUSS THE MERITS OF ANY CASE. (UPDATED 6/17/2020) 

IMPORTANT:  In light of the COVID-19 emergency, the Court encourages all parties to appear remotely.  The capacity in the courtroom is extremely limited.  The Court appreciates the cooperation of counsel and the litigants. 

ALSO NOTE:  If the moving party does not contact the court to submit on the tentative and does not appear (either remotely or in person), the motion will be taken off calendar.  THE TENTATIVE RULING WILL NOT BE THE ORDER OF THE COURT.




Case Number: 19STCV13516    Hearing Date: January 13, 2023    Dept: 29

TENTATIVE 

 

Plaintiff Kelly Lisa Ripley’s motion for terminating, evidentiary, issue, and monetary sanctions is DENIED.  

 

Evidentiary Objections

 

Plaintiff’s Objections to Defendant’s Evidence:

 

·         The following objections are OVERRULED: 1, 3

 

·         The following objections are SUSTAINED: 2

 

Legal Standard  

 

Pursuant to Code of Civil Procedure section 2023.030, the Court may impose the types of sanctions requested depending on the misconduct that occurred.  In general, a nonmonetary sanction is only appropriate after a party fails to obey an order compelling discovery.  (New Albertsons, Inc. v. Superior Court (2008) 168 Cal.App.4th 1403, 1426.)  However, such relief may be imposed without a prior order compelling discovery if obtaining such an order would be futile or the misconduct in connection with the failure to produce evidence in discovery is “sufficiently egregious.”  (Ibid.) 

 

Spoliation of evidence in response to, or in anticipation of, a discovery request may constitute a misuse of the discovery process within the meaning of section 2023.030.  (Cedars-Sinai Medical Center v. Superior Court (1998) 18 Cal.4th 1, 12.)  The term “spoliation” refers to “the destruction or significant alteration of evidence, or the failure to preserve properly for another’s use as evidence in pending or reasonably foreseeable litigation.”  (Reeves v. MV Transp., Inc. (2010) 186 Cal.App.4th 666, 681, internal quotation marks omitted.) 

 

Discussion

 

Plaintiff seeks terminating, issue, and evidentiary sanctions for Defendant’s alleged spoliation of evidence. 

 

New Albertsons is on point.  There, a man slipped and fell while shopping at a supermarket, and he filed suit against the supermarket for negligence and premises liability.  (New Albertsons, supra, 168 Cal.App.4th at p. 1408.)  After receiving the complaint, a request to preserve video footage of the incident, and a request for production of the footage during the course of discovery, the supermarket permitted the footage to be erased, determining that there was no footage of the area where the man fell.  (Id. at pp. 1410-1415.)  Based on this conduct, the trial court imposed evidence and issue sanctions on the supermarket, despite the absence of an order compelling production of the footage or the failure to obey such an order.  (Id. at p. 1427.)  Specifically, the trial court (1) precluded the supermarket from entering into evidence or referring to any part of the video recordings, and (2) provided for a jury instruction that the supermarket destroyed the video recordings after receiving notice to preserve them and after reviewing them, and that the jury may infer that the destroyed recordings were unfavorable to the supermarket.  (Ibid.) 

 

The Court of Appeal granted the supermarket’s writ petition, directing the trial court to vacate its sanctions order.  The Court concluded that “the discovery statutes provide no basis for the sanctions imposed.  Neither the failure to produce video recordings in response to the first set of inspection demands nor the destruction of the recordings in these circumstances justifies an evidence or issue sanction absent a failure to obey an order compelling discovery.”  (New Albertsons, supra, 168 Cal.App.4th at p. 1428.)  The Court also noted that the supermarket automatically recorded over its video recordings in the ordinary course of business, and addressed the concern that in such circumstances plaintiffs might bring meritless spoliation claims.  (Id. at p. 1431.)  The Court stated, “A party moving for discovery sanctions based on the intentional destruction of evidence could argue that the mere fact that the evidence no longer exists supports an inference of intentional spoliation.  Rather than decide the facts with respect to the intentional destruction of evidence and impose a nonmonetary sanction on a pretrial motion in circumstances not contemplated by the discovery statutes, we believe that in most cases of purported spoliation the facts should be decided and any appropriate inference should be made by the trier of fact after a full hearing at trial.”  (Ibid.) 

Here, Plaintiff contends that Defendant intentionally destroyed video footage of her slip and fall.  Plaintiff argues that Defendant destroyed the surveillance video of the store that was recorded at the time of the incident. Defendant’s person most qualified Kimberly Sandoval testified in her deposition when an incident like Plaintiff’s occurs, employees are trained as to what to look for when reviewing video footage after someone falls – that is, after a fall employees are trained to bookmark for preservation video footage of the customer entering the store, leaving the store, and the fall itself; that Ms. Sandoval had applied that training to other videos of falls at the store; that Ms. Sandoval had gone through the video review process once specifically at the subject store because someone fell in the produce section; and that, at minimum, if training procedures were followed for preservation of video footage for the subject incident, there would have been video footage of Plaintiff entering and leaving the store. Lastly, Ms. Sandoval further testified to at least actually seeing video footage of Plaintiff entering and leaving the store. As such, she confirmed video from the day of the incident actually existed. Additionally, Ms. Sandoval testified that the video footage would have shown when she began her last walk through. Now, she is claiming to have done a walk through 20 minutes prior to Plaintiff’s incident and the most credible evidence of that would be the destroyed video footage that she admits existed.

However, Defendant argues that there is no evidence submitted to support Plaintiff’s argument that the incident video was destroyed. The lines from the deposition transcripts quoted by Plaintiff simply do not support that claim. Bookmarking the video does not mean that it was permanently saved, and Plaintiff’s inference that the video must have been destroyed because it was not preserved is just that: an inference not supported by facts or law. In the course of the deposition of Defendant’s PMQ Sandoval, Sandoval made it clear that she had reviewed the incident video, but it did not depict Plaintiff’s actual fall.

Q. Did you at any point in time attempt to view any video of the incident?

A. Yes.

Q. And were you able to observe any video of the Plaintiff at the store with or without falling?

A. Just her entering and her leaving.

Q. Okay. How did she leave the store?

A. On a gurney.

Q. By -- by paramedics or -- or ambulance; is that correct?

A. Yes.

Q. All right. How did she enter the store, walked 9 on her own two feet?

A. Yes.

Q. Okay. While observing the video of her entering the store, did you notice anything out of the ordinary by the way she was walking?

A. I don't remember.

Q. Okay. Did you keep the video of her entering the store? Let me rephrase. That's a bad question. Did you instruct anybody to keep the video of her entering the store?

A. I don't remember if I kept it. I don't remember if I bookmarked it.

Q. Okay. Did you instruct anybody to keep the video of her leaving the store on a gurney?

A. No. (Plaintiff’s Exhibit 3 – Kimberly Sandoval PMQ Depo. p. 56:20- 57:40).

Asked again in a slightly different manner regarding whether the incident was captured on video, Ms. Sandoval testified as follows:

Q. Okay. Did you observe any video during your review of the video of the customer falling?

A. No.

Q. Were you able to observe any video that captured the floral department?

A. No.

(Plaintiff’s Exhibit 3 – Kimberly Sandoval PMQ Depo. p. 59:11-16).

Therefore, Defendant argues, there is nothing in Ms. Sandoval’s testimony to support that conclusion that she intentionally destroyed evidence or had any knowledge that video of the actual incident existed in the first place. Moreover, Defendant argues the video did not depict the floral area.

The motion for nonmonetary sanctions is denied.  There has been no order compelling Defendant to produce the footage, and under the general rule, nonmonetary sanctions are therefore inappropriate. “The discovery statutes provide no basis for the sanctions imposed.  Neither the failure to produce video recordings in response to the first set of inspection demands nor the destruction of the recordings in these circumstances justifies an evidence or issue sanction absent a failure to obey an order compelling discovery.” (New Albertsons, supra, 168 Cal.App.4th at p. 1428.) Plaintiff argues that this is not a discovery motion and thus, New Albertsons does not apply. However, Plaintiff, in her own motion, stated it is. Plaintiff wrote: “Defendant Smart & Final knew it was important to preserve video evidence, Defendant’s own employees even saw video footage of Plaintiff entering the store, yet it was not produced in discovery.”  (Motion, pg. 12, ls. 3-5.) Thus, this argument is unavailing.  

In addition, Plaintiff also has not established Defendant actually destroyed or failed to preserve evidence, as it does not appear the evidence of Plaintiff’s fall exists. While it appears that evidence of Plaintiff entering and exiting the store exists, for the reasons discussed in New Albertsons, pretrial, nonmonetary sanctions of the type sought by Plaintiff are not appropriate in these circumstances under the discovery statutes. “Rather than decide the facts with respect to the intentional destruction of evidence and impose a nonmonetary sanction on a pretrial motion in circumstances not contemplated by the discovery statutes, we believe that in most cases of purported spoliation the facts should be decided and any appropriate inference should be made by the trier of fact after a full hearing at trial. (New Albertsons, supra, 168 Cal.App.4th at p. 1431.)

Not only that, but Plaintiff has not filed a separate statement, and the motion for issue and evidentiary sanctions are also denied on that ground. A motion for issue or evidentiary sanctions must be accompanied by a separate statement. (Cal. Rules of Court, rule 3.1345(a)(7).)

Lastly, Plaintiff’s request for monetary sanctions is denied for the same reason. Additionally, Plaintiff did not, in the notice of motion, identify who she seeks monetary sanctions against. The notice of motion must “identify every person, party, and attorney against whom the sanction is sought, and specify the type of sanction sought.” (C.C.P. § 2023.040.) Defendant’s request for sanctions against Plaintiff is denied for the same reason. (C.C.P. § 2023.040.)

 

Conclusion

 

Accordingly, Plaintiff’s motion for terminating, evidentiary, issue and monetary sanctions is DENIED.  

 

Moving party is ordered to give notice.