Judge: Serena R. Murillo, Case: 22STCV11053, Date: 2023-08-15 Tentative Ruling

Case Number: 22STCV11053    Hearing Date: August 15, 2023    Dept: 31

TENTATIVE

 

Defendants’ demurrer is SUSTAINED with leave to amend in part and OVERRULED in part. The demurrer is sustained with 30 days leave to amend as to the first cause of action for Violation of Civil Code §¿1942.4, and the twelfth cause of action for trespass. The demurrer is overruled as to the cause of action for negligent hiring, supervision, and retention.

 

Legal Standard 

 

A demurrer for sufficiency tests whether the complaint states a cause of action. (Hahn v. Mirda (2007) 147 Cal.App.4th 740, 747.) When considering demurrers, courts read the allegations liberally and in context. (Taylor v. City of Los Angeles Dept. of Water and Power (2006) 144 Cal.App.4th 1216, 1228.) The court “treat[s] the demurrer as admitting all material facts properly pleaded, but not contentions, deductions or conclusions of fact or law ….” (Berkley v. Dowds (2007) 152 Cal.App.4th 518, 525).) 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 pleadings alone and not the evidence or other extrinsic matters; therefore, it lies only where the defects appear on the face of the pleading or are judicially noticed. (Code Civ. Proc., §§ 430.30, 430.70.) The only issue involved in a demurrer hearing is whether the complaint, as it stands, unconnected with extraneous matters, states a cause of action. (Hahn, supra, 147 Cal.App.4th at 747.) 

 

Meet and Confer 

 

The demurrer and motion to strike are accompanied by the declaration of H.G. Long which satisfies the meet and confer requirement. (Code Civ. Proc. § 430.41.)  

 

Discussion

 

First Cause of Action (Violation of Civil Code §¿1942.4)

 

"… [T]here is a statutory cause of action available to the residential tenant where the premises are untenantable and other circumstances exist. Under Civil Code section 1942.4, a residential landlord may not demand or collect rent, increase rent, or serve a three-day notice to pay rent or quit if (1) the dwelling is untenantable as defined under section 1941.1, is in violation of section 17920.10 of the Health and Safety Code, or is deemed and declared substandard under section 17920.3 of the Health and Safety Code; (2) a public officer inspects the premises and gives the landlord written notice that it must abate the nuisance or repair the property; (3) the conditions have not been remedied within 35 days of the notice; and (4) the substandard conditions were not caused by the tenant's acts or omissions. (Civ. Code, § 1942.4, subd. (a).) In the event that each of the circumstances under subdivision (a) of the statute is satisfied, a tenant may bring an action for actual damages plus statutory damages of between $100 and $5,000. (Civ. Code, § 1942.4, subd. (b)(1).)" (Erlach v. Sierra Asset Servicing, LLC (2014) 226 Cal.App.4th 1281, 1298.) 

 

Defendants argue that nowhere does Plaintiff allege the written notification by a public officer or employee responsible for enforcement of housing law, or that Defendants did not abate the condition or conditions within35 days. There is also no allegation that the failure to abate within 35 days was not with good cause.

 

The Court agrees that there are no allegations regarding whether a public officer inspected the premises and gave the landlord written notice that it must abate the nuisance or repair the property; and that the conditions have not been remedied within 35 days of the notice. The complaint says nothing about a public officer inspecting the premises and giving Defendants notice to abate or repair, or that the conditions have not been remedied within 35 days of that officer’s notice. The complaint merely alleges the conditions were not remedied within days of Plaintiff’s notice to correct the defective conditions at the property. (Complaint, 75.) This is not what the statute requires.

 

As a result, the demurrer to the first cause of action is SUSTAINED with leave to amend.

Ninth Cause of Action (Negligent Hiring, Retention, and Supervision)

A cause of action for negligent hiring, supervision, or retention of an employee requires the following elements: (1) the employer hired employee; (2) the employee was/became unfit or incompetent to perform the work for which he was hired; (3) the employer knew or should have known the employee was/became unfit or incompetent and that this unfitness or incompetence created a particular risk to others; (4) the employee’s unfitness or incompetence harmed plaintiff; and (5) the employer’s negligence in hiring/supervising/ retaining the employee was a substantial factor in causing plaintiff’s harm.  (CACI No. 426; see also Federico v. Superior Court (1997) 59 Cal.App.4th 1207, 1213-1214.)  To establish a cause of action for negligent hiring, retention, or supervision, a plaintiff must show that the employer knew or should have known that hiring or retaining the employee created a particular risk or hazard and that particular harm occurs.  (See Z.V. v. County of Riverside (2015) 238 Cal.App.4th 889, 902; Doe, supra, 50 Cal.App.4th at 1054.)  Negligent hiring, retention, or supervision is a form of direct negligence.  (Ibid.) 

Defendant argues that the ninth cause of action is alleged against both defendants, including against Mark Barnes. However, the complaint alleges that Mark Barnes is the agent of Forrest. Therefore, the agent/employee cannot be negligent in its own hiring.

Plaintiff concedes this point, but maintains that throughout the cause of action, it is clear that the charges for negligent hiring, retention, and supervision are against Defendant Forrest Barnes. Paragraphs 139, 141, and 143 demonstrate that the conduct at bar in the Ninth Cause of Action is charged against the Defendant Forrest Barnes.

The Court agrees the allegations are directed to Forrest Barnes, and not Mark Barnes, and Plaintiff admits she does not allege this cause of action against Mark Barnes. Thus, the demurrer is OVERRULED as to the ninth cause of action for negligent hiring, retention and supervision.

              Twelfth Cause of Action (Trespass)

Code of Civil Procedure section 338(b) provides for a three-year statute of limitations for “[a]n action for trespass upon or injury to real property.”

 

Where the dates alleged in the complaint show the action is barred by the statute of limitations, a general demurrer lies. ¿(Saliter v. Pierce Bros. Mortuaries (1978) 81 Cal.App.3d 292, 300.)

The complaint alleges that “Plaintiffs are informed and believe and thereon allege that Defendants entered the Subject Property in October of 2015. Plaintiff had installed an alarm system in the Subject Property, such that when the Defendants entered the Property without Plaintiffs knowledge or consent while she was not home, the alarm was triggered. Plaintiff alleges that Defendants quickly departed from the Subject Property, but nonetheless are guilty of trespass.” (Complaint, 164.) Plaintiff filed this action on March 30, 2022.

Plaintiff contends that the three-year limitations period does not bar Plaintiff’s cause of action because Defendants have engaged in a pattern and practice of trespassing in the Subject Property, including trespassing which has occurred in the past three years.  

Here, the Complaint does not allege any facts to show the trespass has continued beyond 2015. Since the Complaint does not set forth any facts supporting Plaintiff’s contention, the three-year statute of limitations under CCP § 338(b) is applicable to these actions for trespass. 

 

Accordingly, the Court SUSTAINS the demurrer to the twelfth cause of action, with leave to amend.  

Conclusion

Based on the foregoing, the demurrer is SUSTAINED with leave to amend in part and OVERRULED in part. The demurrer is sustained with 30 days leave to amend as to the first cause of action for Violation of Civil Code §¿1942.4, and the twelfth cause of action for trespass. The demurrer is overruled as to the cause of action for negligent hiring, supervision, and retention.

Moving party is ordered to give notice.