Judge: Shirley K. Watkins, Case: 19STCV37977, Date: 2023-03-08 Tentative Ruling

Case Number: 19STCV37977    Hearing Date: March 8, 2023    Dept: T

3/8/2023

SALINAS v TRANSIT 19STCV37977

      CONSOLIDATED WITH:

      19STCV41653,20STCV39458,19STCV 44511,

      20STCV17386,20STCV35396, 20STCV37023,

      20STCV38966,20STCV39216, 20STCV39249,

      20STCV36631

 

            RELATED WITH: 21STCV07756

[TENTATIVE] ORDER RE:

1. MOTION FOR SUMMARY JUDGMENT OR ALTERNATIVELY FOR SUMMARY ADJUDICATION AGAINST PLAINTIFFS ARCELIA QUINTEROS AND MIGUEL IBARRA’S COMPLAINT BY DEFENDANT THE UNIVERSAL CHURCH, INC.

2. MOTIONS FOR SUMMARY JUDGMENT OR ALTERNATIVELY FOR SUMMARY ADJUDICATION AGAINST PLAINTIFF ROSA PANIAGUA GONZALEZ’S COMPLAINT BY DEFENDANT THE UNIVERSAL CHURCH, INC.

3. MOTION FOR SUMMARY JUDGMENT AGAINST PLAINTIFF ISABEL LOPEZ LEMUS’ COMPLAINT BY DEFENDANT THE UNIVERSAL CHURCH, INC.

[TENTATIVE] ORDER:

            1.         Defendant The Universal Church, Inc.’s Motion for Summary Judgment and alternatively for Summary Adjudication against Plaintiffs Arcelia Quinteros and Miguel Ibarra’s Complaint is DENIED.

            2.         Defendant The Universal Church, Inc.’s Motion for Summary Judgment and alternatively for Summary Adjudication against Plaintiff Rosa Paniagua Gonzalez’s Complaint is GRANTED.

            3.         Defendant The Universal Church, Inc.’s Motion for Summary Judgment against Plaintiff  Isabel Lopez Lemus’ Complaint is DENIED.

            4.         Plaintiffs Arcelia Quinteros and Miguel Ibarra’s Request for Joinder in Co-Plaintiffs' oppositions is DENIED.

INTRODUCTION

Defendant The Universal Church, Inc. (Defendant) filed a motion for summary judgment (MSJ) and alternatively a motion for summary adjudication (MSA) against the Complaint titled, ARACELI QUINTEROS and MIGUEL IBARRA v. TRANSIT SYSTEMS UNLTD., INC., et al., Case No. 20STCV17386 (MSJ/MSA reservation no. ending in x5798).  Defendant’s MSA against Quinteros Plaintiffs’ Complaint asserted two issues: (1) Issue 1 is against the first Cause of Action (COA) for motor vehicle liability; and (2) Issue 2 is against the second COA for negligence.  Plaintiffs Araceli Quinteros and Miguel Ibarra are collectively referred to as “Quinteros Plaintiffs.”

Defendant filed an MSJ/MSA against the Complaint titled, ROSA PANIAGUA GONZALEZ v. TRANSIT SYSTEMS UNLTD., INC., et al., Case No. 20STCV37023 (MSJ/MSA reservation no. ending in x6514.)  Defendant’s MSA against Gonzalez’s Complaint asserted two issues: (1) Issue 1 is against the first COA for motor vehicle liability; and (2) Issue 2 is against the second COA for negligence.  Plaintiff Rosa Paniagua Gonzalez is referred to as “Gonzalez Plaintiff.”

Defendant filed an MSJ only against the Complaint filed in ISABEL LOPEZ LEMUS v. OFELIA SANDOVAL RODRIGUEZ et al., Case No. 19STCV44511 (MSJ reservation no. ending in x1145.) Plaintiff Isabel Lopez Lemus is referred to as “Lemus Plaintiff.”   Lemus Plaintiff’s Complaint only alleged a single COA for negligence.

All responding party plaintiffs are collectively referred to as “Plaintiffs.”

PROCEDURE

Quinteros Plaintiffs requested joinder to the Oppositions filed by Co-Plaintiffs.  However, Quinteros Plaintiffs failed to submit a Separate Statement addressing the Separate Statements filed by Defendant against Co-Plaintiffs.  Defendant filed Separate Statements that were different for each set of Plaintiffs.  Quinteros Plaintiffs request for joinder is DENIED.

Defendant argued that Gonzalez Plaintiff’s separate statement did not respond to the 44 facts presented in Defendant’s separate statement but listed 26 facts that is the number of facts stated in the separate statement attached to Defendant’s MSJ against Lemus Plaintiff’s Complaint.  The opposing party's failure to comply with the separate statement requirement may, in the court's discretion, constitute a sufficient ground for granting the motion.  (Code Civ. Proc. sec. 437c(b)(3); Oldcastle Precast, Inc. v. Lumbermens Mut. Cas. Co. (2009) 170 Cal.App.4th 554, 568; Batarse v. Service Employees Int'l Union Local 1000 (2012) 209 Cal.App.4th 820, 831-833.)  Although Gonzalez Plaintiff’s separate statement addressed the wrong separate statement filed by Defendant, the Court exercised its discretion and reviewed the 26 facts presented in Gonzalez Plaintiff’s separate statement as being responsive to Defendant’s 44 facts stated in Defendant’s separate statement.

DISCUSSION

Defendant argued that there is no triable issue of fact as to Quinteros Plaintiffs' and Gonzalez Plaintiff’s first and second COAs and Lemus Plaintiff’s sole COA for negligence because there are no disputed material facts to show direct negligent conduct and a vicarious relationship with Co-Defendants U.S. Coachways (Coachways,) Transit Systems (Transit,) or Ofelia Rodriguez (Rodriguez.)  Defendant provided testimony/facts from Maurice Venegas (Venegas,) Transit’s person most knowledgeable, and Rodriguez, to show that Defendant did not own, operate, manage, entrust, permit, control, or drive the bus either directly or through Rodriguez, the driver.  (Defendant’s Separate Statement of Facts as to Quinteros Plaintiffs (DSSFQP) 3-4, 11-13, 27-28, and 35-37; Defendant’s Separate Statement of Facts as to Gonzalez Plaintiff (DSSFGP 2-3, and 24-25; Defendant’s Separate Statement of Facts as to Lemus Plaintiff (DSSFLP) 2-3.)  Defendant provided testimony/facts from Venegas and Rodriguez, again, to show that Defendant did not employ or enter any agency relationship with Coachways, Transit, or Rodriguez.  Defendant also provided as to Lemus Plaintiff’s MSJ that Defendant did not train, instruct, supervise, or direct Rodriguez.  (DSSFQP 5-6, 14-15, 18-24, 29-30, 38-39, and 42-48; DSSFGP 4-6, 13-19, 26-28, and 35-41; DSSFLP 4-6, 11-15, and 18-26.)  Further, Defendant provided facts to show that non-party American Fleet Services and third-party vendors maintained, repaired, serviced, or inspected the bus.  (DSSFQP 7-10, and 31-34; DSSFGP 7-10, and 29-32; DSSFLP 7-10.)  Based upon these facts/testimony/evidence, Defendant met their burden of proof to show that there is no triable issue of material fact as to the first and second COAs claim that Defendant owned, operated, managed, entrusted, permitted, controlled, drove, maintained, repaired, serviced, or inspected the bus at issue; or employed, or entered any agency relationship with any Co-Defendants.  The burden of proof shifted to Plaintiffs to show that a triable issue of material fact exists.

Plaintiffs argued four legal grounds to support the argument that a triable issue of material facts exists: ownership, ratification; ostensible agency; and Defendant employed Rodriguez.  To support these legal theories, Quinteros and Lemus Plaintiffs provided that Defendant advertised through a flier that stated, “Come grab your seat ticket with us!” and “Reserve your seat… with us.”  (Quinteros Plaintiffs’ Separate Statement of Disputed Facts (QPSSDF) 1-6, 11-24, 25-30, and 35-48; Lemus Plaintiff Separate Statement of Disputed Facts (LPSSDF) 2-6, 11-15, 18-19, 23-24, and 26.)  Defendant objected to the submission of the flier because Plaintiffs did not previously produce the flier during discovery and only produced the flier for the first time in Plaintiffs’ opposition to the MSJ/MSA to “create” disputed facts.  Defendant argued that the Court has authority to disregard the flier.  (Field v. U.S. Bank N.A. (2022) 79 Cal.App.5th 703, 705 (Field.))  Preliminarily, the response at issue in the Field case was a one-word response of, “Unsure,” to a contention interrogatory asking if Plaintiff Field asserted that the Notice of Trustee Sale (NTS) was not mailed to her.  The Court found that the response was ambiguous and obfuscated the grounds for Plaintiff Field’s basis for her wrongful foreclosure claims – failure to mail the NTS.  The Court opined that Plaintiff Field could not create a disputed fact in opposing an MSJ/MSA with an assertion she had failed to formulate or to disclose during discovery.  (Id. at pg. 708.)  Quinteros Plaintiffs’ responses, in summary, stated that they were not in possession of facts to respond to the discovery and that their investigation was on-going.  (See Defendant’s Quinteros Plaintiffs’ Exhs. 10-15, Quinteros Plaintiffs’ Responses to Request for Admissions (RFA) 13 and 15; Quinteros Plaintiffs’ Responses to Form Interrogatory (FI) 17.1; and Quinteros Plaintiffs’ Responses to Special Interrogatories (SI) 1-2.)  Lemus Plaintiff responses to Defendant’s special interrogatories, in summary, stated that Lemus Plaintiff believed that Rodriguez was an agent or employee of Defendant based upon the fact that Defendant hired Transit.  Quinteros and Lemus Plaintiffs’ responses were not ambiguous but straightforward.  Further, there are no facts to show obfuscation of the grounds for the negligence claim – agency.  Quinteros and Lemus Plaintiffs expressly alleged in the Complaint that agency was a legal theory upon which liability was being alleged.  Defendant also argued in their MSJ/MSA that there were no triable issues of fact as to agency, and more specifically ostensible agency.  Another glaring difference between the evidence at issue in Field and the instant action is that Plaintiff Field was the only party in “possession” of the fact/evidence that the NTS was not mailed.  In the instant action, the flier being presented by Quinteros and Lemus Plaintiffs was created by Defendant and in Defendant’s possession.  Defendant’s argument presumes that Quinteros and Lemus Plaintiffs and/or their Counsel were the only ones in possession of the flier prior to the filing of the Complaint and through responses to discovery were served.  Defendant failed to present any facts/evidence to support such a presumption.  Without such facts, Defendant failed to show that Quinteros and Lemus Plaintiffs “hid the ball.”  Defendant’s objection to the flier based upon Field is unpersuasive and the Court considered Quinteros and Lemus Plaintiffs’ arguments based upon the flier and that Defendant allegedly controlled the reservation of seats on the bus.

Specifically as to Gonzalez Plaintiff, Gonzalez Plaintiff failed to submit any declarations in support of the opposition.  Without declarations, the exhibits are unauthenticated and inadmissible.  Without admissible exhibits, Gonzalez Plaintiff’s opposition and separate statement are unsupported with facts, especially as to the flier.  Gonzalez Plaintiff’s contention that Defendant’s flier provided facts to show ownership, ratification, agency, or an employment relationship is merely argument without evidence.  Gonzalez Plaintiff's Separate Statement of Disputed Facts (GPSSDF) 2-6, 11, 13-15, 23, 24, and 26 reliance upon the flier cannot be considered.  Further, without a declaration from Gonzalez Plaintiff, there is no evidence to support the contention that an ostensible agency existed because Gonzalez Plaintiff has not submitted evidence to show that she saw the flier prior to the accident and relied upon it.  On this defect, Gonzalez Plaintiff failed to meet her burden of proof to show that a triable issue of fact exists.  Defendant’s MSJ/MSA as to Gonzalez Plaintiff is GRANTED.

Quinteros and Lemus Plaintiffs argued that Transit and/or Rodriguez were ostensible agents of Defendant.  At issue is not an express agency but an ostensible agency.  The essential elements of ostensible agency are: (1) a representation (or omission) by the principal (some act or neglect by the principal sought to be charged leading plaintiff reasonably to believe the third person was the principal's agent/employee);  (2) plaintiff's justifiable reliance thereon (plaintiff dealt with the supposed agent in the reasonable belief he or she (defendant) was authorized to act on the principal's behalf and was not negligent in relying upon the supposed agent's apparent authority);  (3) plaintiff's change of position or injury resulting from such reliance.  (Civ. Code sec. 2300; Markow v. Rosner (2016) 3 Cal.App.5th 1027, 1038; CACI 3709.)  In order to establish an agency relationship, there must be conduct showing the principal's sufficient right to control the agent.  (Secci v. United Indep. Taxi Drivers, Inc., (2017) 8 Cal.App.5th 846, 855.)  With the statements in the flier, Quinteros and Lemus Plaintiffs presented evidence showing that there is a triable issue as to Defendant controlled the seating on the bus since Defendant was the sole point-of-contact for the bus ride to the event.  This is sufficient evidence to show a triable issue as to Defendant’s representation on the first element for ostensible agency.  Quinteros and Lemus Plaintiffs' evidence supports their claim that they justifiably relied upon the representation by making their seat reservation on the bus through Defendant.  Neither party presented facts/evidence to show Quinteros and Lemus Plaintiffs were negligent in relying upon the representation.  Lastly, Quinteros and Lemus Plaintiffs’ evidence support their claim that they were injured as a result of their reliance.  The Court finds that these facts are sufficient to raise a triable issue of material fact as to ostensible agency and is grounds to deny the MSJ/MSA as to Quinteros Plaintiffs and the MSJ as to Lemus Plaintiff.

The Court did not consider Plaintiffs’ facts to show that Defendant had complete dominance over the event and/or Plaintiffs’ argument/contention that Defendant acquired liability insurance for the bus.  The Court sustained Defendant’s objection to Quinteros and Lemus Plaintiff Counsel’s declaration which contained the testimony as to liability insurance.  In any event, Quinteros and Lemus Plaintiffs’ Exhibits Bate Stamp 000057-000058 does not show that Defendant “acquired” the policy; it only shows that Defendant is a “Certificate Holder” and the company acquiring the insurance is American Tour & Travel, Inc. – the insured.  Plaintiffs’ contention that Defendant “acquired” the policy is not supported by its submitted evidence.

Quinteros and Lemus Plaintiffs further argued that Defendant ratified Transit/Rodriguez’s negligence.  “[A]n agency may be created, and an authority may be conferred, by a precedent authorization or a subsequent ratification.”  (Civ. Code sec. 2307.) “Ratification is the voluntary election by a person to adopt in some manner as his own an act which was purportedly done on his behalf by another person, the effect of which, as to some or all persons, is to treat the act as if originally authorized by him.  [Internal citation omitted.]”  (Rakestraw v. Rodrigues (1972) 8 Cal.3d 67, 73.) “A purported agent’s act may be adopted expressly or it may be adopted by implication based on conduct of the purported principal from which an intention to consent to or adopt the act may be fairly inferred, including conduct which is ‘inconsistent with any reasonable intention on his party, other than that he intended approving and adopting it.  [Internal citation omitted.]’”  (Id.)  Quinteros and Lemus Plaintiffs first argued that Defendant had prior knowledge that Transit/Rodriguez would be providing transportation services and failed to disavow Transit/Rodriguez’s services.  However, ratification requires conduct subsequent to the negligent act.  Defendant’s prior knowledge is insufficient to show subsequent conduct.  Further, Defendant’s "failure to disavow" is only evidence of “silence” and “silence” does not show an intention to consent to or adopt the negligent act.  Quinteros and Lemus Plaintiffs’ argument as to ratification is not persuasive to show a triable issue of fact as to agency created by subsequent ratification.

Quinteros and Lemus Plaintiffs also argued that there is evidence that an employment relationship was created directly with Rodriguez based upon the flier.  However, the flier makes no representations referencing Rodriguez.  The flier only had a picture of a bus and representations that Defendant was the contact to reserve a seat on the bus.  Without evidence specifically referencing Rodriguez, Quinteros and Lemus Plaintiffs’ evidence does not support their contention that an employment relationship was created between Defendant and Rodriguez.   This argument is insufficient to show that a triable issue of fact exists as to any employment relationship between Defendant and Rodriguez.

Defendant’s MSJs/MSAs against Quinteros Plaintiffs’ Complaint and Defendant’s MSJ against Lemus Plaintiff’s Complaint are DENIED.  Defendant’s MSJs/MSAs against Gonzalez Plaintiff Complaint is GRANTED.

_________________________________________________________________________

[TENTATIVE] ORDER RE:

MOTION FOR SUMMARY JUDGMENT OR ALTERNATIVELY FOR SUMMARY ADJUDICATION BY DEFENDANT THE UNIVERSAL CHURCH, INC. AGAINST:

(1)   PLAINTIFFS LUCIDIO SANCHEZ MEJIA, VERONICA GUADALUPE SANCHEZ, ROSALIA GONZAGA HIDALGO, JOSE PABLO ARELLANO, VICTORINO GONZAGA, JR., RAUDEL MUNOZ QUIJAS, LILIANA VICTORIA QUIJAS by and through Guardian Ad Litem RAUDEL MUNOZ QUIJAS, VALERIE VICTORIA QUIJAS by and through Guardian Ad Litem RAUDEL MUNOZ QUIJAS, YURIDIA ARELLANO, ANTONION DIEGO DE JESUS by and through Guardian Ad Litem YURIDIA ARELLANO’s COMPLAINT;

AND

(2)   ROSA URCIEL’S COMPLAINT

[TENTATIVE] ORDER: 

Defendant The Universal Church, Inc.’s Motion for Summary Judgment against Plaintiffs Lucidio Sanchez Mejia, Veronica Guadalupe Sanchez, Rosalia Gonzaga Hidalgo, Jose Pablo Arellano, Victorino Gonzaga, Jr., Raudel Munoz Quijas, Liliana Victoria Quijas by and through Guardian Ad Litem Raudel Munoz Quijas, Valeria Victoria Quijas by and through Guardian Ad Litem Raudel Munoz Quijas, Yuridia Arellano, Antonio Diego De Jesus by and through Guardian Ad Litem Yuridia Arellano’s Complaint is GRANTED.

Defendant The Universal Church, Inc.’s alternative Motion for Summary Adjudication is MOOT as to Issues 1 & 2.

Defendant The Universal Church, Inc.’s Motion for Summary Adjudication is DENIED as to Issue 3 and GRANTED as to Issue 4.

Defendant The Universal Church, Inc.’s Motion for Summary Judgment against Rosa Urciel’s Complaint is MOOT.

Plaintiffs Lucidio Sanchez Mejia, Veronica Guadalupe Sanchez, Rosalia Gonzaga Hidalgo, Jose Pablo Arellano, Victorino Gonzaga, Jr., Raudel Munoz Quijas, Liliana Victoria Quijas by and through Guardian Ad Litem Raudel Munoz Quijas, Valeria Victoria Quijas by and through Guardian Ad Litem Raudel Munoz Quijas, Yuridia Arellano, Antonio Diego De Jesus by and through Guardian Ad Litem Yuridia Arellano, and Rosa Urciel’s Request for Joinder is DENIED.

INTRODUCTION

Defendant The Universal Church, Inc. (Defendant) filed a single MSJ/MSA against two separately filed actions: (1) LUCIDIO SANCHEZ MEJIA, VERONICA GUADALUPE SANCHEZ, ROSALIA GONZAGA HIDALGO, JOSE PABLO ARELLANO, VICTORINO GONZAGA, JR., RAUDEL MUNOZ QUIJAS, LILIANA VICTORIA QUIJAS by and through Guardian Ad Litem RAUDEL MUNOZ QUIJAS, VALERIE VICTORIA QUIJAS by and through Guardian Ad Litem RAUDEL MUNOZ QUIJAS, YURIDIA ARELLANO, ANTONION DIEGO DE JESUS by and through Guardian Ad Litem YURIDIA ARELLANO v. TRANSIT SYSTEMS UNLTD., INC., et al., LASC Case No. 19STCV41653 and (2) ROSA URCIEL v. TRANSIT SYSTEMS UNLTD., INC., et al., LASC Case No. 20STCV39458 (MSJ/MSA reservation no. ending in x2464.)

Plaintiffs Lucidio Sanchez Mejia, Veronica Guadalupe Sanchez, Rosalia Gonzaga Hidalgo, Jose Pablo Arellano, Victorino Gonzaga, Jr., Raudel Munoz Quijas, Liliana Victoria Quijas by and through Guardian Ad Litem Raudel Munoz Quijas, Valeria Victoria Quijas by and through Guardian Ad Litem Raudel Munoz Quijas, Yuridia Arellano, Antonio Diego De Jesus by and through Guardian Ad Litem Yuridia Arellano are collectively referred to as “Mejia Plaintiffs.”  Plaintiff Rosa Urciel is referred to as “Urciel Plaintiff.”

Mejia Plaintiffs and Urciel Plaintiff are collectively referred to as “Plaintiffs.”

Defendant’s MSA presented four issues: (1) Issue 1 is against Mejia Plaintiffs’ first cause of action (COA) for negligence; (2) Issue 2 is against Mejia Plaintiffs' second COA for negligent hiring; (3) Issue 3 is against Urciel Plaintiff’s first COA for negligence; and (4) Issue 4 is against Urciel Plaintiff’s second COA for negligent hiring.

PROCEDURE

Mejia Plaintiffs requested joinder to the Oppositions filed by Gonzalez Plaintiff, Quinteros Plaintiffs, and Lemus Plaintiff.  However, Mejia Plaintiffs failed to submit Separate Statements addressing the Separate Statements filed by Defendant against Gonzalez Plaintiff, Quinteros Plaintiffs, and Lemus Plaintiff.  Defendant filed Separate Statements that are different for each set of plaintiffs.  Mejia Plaintiffs request for joinder is DENIED.

DISCUSSION

A.        MSJ/MSA as to Mejia Complaint

In MSA Issues 1 and 2, Defendant argued that there is no triable issue of fact as to Mejia Plaintiffs’ first COA and second COAs because there are no disputed material facts as to direct liability negligence and as to any vicarious relationship with Co-Defendants U.S. Coachways (Coachways,) Transit Systems (Transit,) or Ofelia Rodriguez (Rodriguez.)  Under the first COA, Mejia Plaintiffs alleged that Defendant negligently owned, operated, hired, supervised, trained, controlled, maintained, inspected, repaired the bus, or negligently failed to install safety devices.  Defendant provided testimony/facts from Maurice Venegas (Venegas,) Transit’s person most knowledgeable, and Rodriguez, supporting its position that Defendant did not own, operate, inspect, or control the bus either directly or vicariously.  (Defendant’s Separate Statement of Facts (DSSF) 2-3, 5, 12-14.)  Because evidence is presented supporting the position that Defendant did not own, operate, inspect, or control the bus, Defendant met its initial burden to show that no triable issue of fact exists as to these claims.

Defendant presented facts to show support its position that non-party American Fleet Services and third-party vendors maintained, inspected and/or repaired the bus.  (DSSF 9-11.)  Because evidence is presented by Defendant supporting its position that third-party entities maintained, inspected, or repaired the bus, it is established its prima facie defense that there is no triable issue of fact as to these claims for negligence.

Defendant argued that there is no triable issue of fact as to Mejia Plaintiffs’ claims related to the lack of seat belts.  With Defendant’s facts supporting its claim showing lack of ownership, there is no triable issue of fact that Defendant owed a duty to either provide seat belts or move any concerned Plaintiffs onto another bus or warn passengers that the bus did not have seat belts.  Defendant submitted Vanegas’ testimony to show his understanding that regulations did not require seat belts on the bus at issue.  (Motion Exh. 7 at 8:9-11; 115:4-15; and Brinkerhoff Decl. pars. 6-7.)  Because Defendant’s evidence supports its position that there is no triable issue of fact as to ownership of the bus and no triable issue of fact as to an affirmative duty regarding the seat belts, Defendant has sufficiently met its initial burden of proof as to these claims.

Defendant again provided testimony/facts from Venegas and Rodriguez to support its position that Defendant did not hire, train, supervise, retain, employ, or enter any agency relationship with Coachways, Transit, or Rodriguez.  Rodriguez testified that she worked for Transit.  Defendant asserted that Transit was not employed by or an agent of Defendant.  Defendant’s facts support its position that Defendant did not control Rodriguez or the buses. (DSSF 6-8, 15-17, 21-27.)  Based upon these facts, Defendant met its burden of proof to show that there is no triable issue of material fact as to Mejia Plaintiffs’ first and second COAs’ claim that Defendant hired, trained, supervised, retained, employed, or entered any agency relationship with any Co-Defendants.

As Defendant met its initial burden of proof as to Issues 1 & 2, then the burden shifted to Mejia Plaintiffs to show that a triable issue of fact exists.

Mejia Plaintiffs’ separate statement did not dispute most of Defendant’s evidence in support of the issues of ownership, operation, management, entrustment, permission, control, driving, maintenance, repair, service, inspection, hiring, training, supervision, and retention.  However, as to claims based upon vicarious liability (i.e., employment and agency,) Mejia Plaintiffs disputed Defendant’s denial of any agency relationship.  Mejia Plaintiffs’ separate statement asserted disputes as to DSSF 8, 15, 17, 35, 42, 44.  Mejia Plaintiffs asserted that Rodriguez was Defendant’s employee through ostensible agency.  The essential elements of ostensible agency are: (1) a representation (or omission) by the principal (some act or neglect by the principal sought to be charged leading plaintiff reasonably to believe the third person was the principal's agent/employee); (2) plaintiff's justifiable reliance thereon (plaintiff dealt with the supposed agent in the reasonable belief he or she (defendant) was authorized to act on the principal's behalf and was not negligent in relying upon the supposed agent's apparent authority);  (3) plaintiff's change of position or injury resulting from such reliance.  (Civ. Code sec. 2300; Markow v. Rosner (2016) 3 Cal.App.5th 1027, 1038; CACI 3709.)  However, the deposition testimony of Mejia Plaintiffs to support these facts fail to present any evidence to show that Defendant made a representation to Mejia Plaintiffs or that Mejia Plaintiffs justifiably relied upon the representation.  None of Mejia Plaintiffs’ deposition testimony presented any evidence in support that Mejia Plaintiffs relied upon a flyer or any advertisement by Defendant.  (Mejia Plaintiffs’ Additional Facts (MPAF) 109-110, 116.)  Further, Mejia Plaintiffs’ reliance upon declarations from Co-Plaintiffs Isabel Lemus, Miguel Ibarra, and Arcelia Quinteros is unavailing to show a triable issue as to the first two elements for ostensible agency because representations made to Co-Plaintiffs are insufficient to show that representations were made to Mejia Plaintiffs by Defendant.  Mejia Plaintiffs’ arguments as to ostensible agency is insufficient to raise a triable issue of material fact as to vicarious liability on their claims.  Mejia Plaintiffs’ arguments as to ostensible agency are insufficient to meet their burden to show the existence of a triable issue of fact on their claims.

Mejia Plaintiffs then argued that Defendant had a duty to provide safe transportation to and from the event, and such duty was non-delegable to Co-Defendants.  However, a “duty to provide safe transport” is merely a generalized characterization of the specific duties addressed above.  Safe transportation of passengers is necessarily encompassed within the duty of care resulting from ownership, operation, management, entrustment, permission, control, driving, maintenance, repair, service, inspection, hiring, training, supervision, retention, providing safety devices, manufacture, assembly, and/or sale.  A claim that there is a “duty to provide safe transport” alone is insufficient to assert a viable duty of care.

Mejia Plaintiffs argued that the duties of care at issue are non-delegable.  However, this is a non-sequitur argument because the duties of care resulting from ownership, operation, management, entrustment, permission, control, driving, maintenance, repair, service, inspection, hiring, training, supervision, retention, providing safety devices, manufacture, assembly, and sale can apply to Defendant, only if it has direct liability or vicarious liability.  The review above applied the duties as not being delegable because there was insufficient evidence presented by the Mejia Plaintiffs to support a triable issue of fact on either direct or vicarious liability.

Defendant met its initial burden to show that no triable issue of fact exists as the first and second COAs alleged by Mejia Plaintiffs.  Mejia Plaintiffs failed to meet their burden to show that a triable issue of facts exists.

Defendant’s MSJ as to Mejia Plaintiffs' Complaint is GRANTED.  Defendant’s MSA is MOOT as to Issues 1 & 2.

B.        MSJ/MSA as to Urciel Complaint:

For MSA Issue 3 and 4, Defendant argued that there is no triable issue of fact as to Urciel Plaintiff’s first COA and second COAs because there are no disputed material facts as to direct liability negligence and as to any vicarious relationship with Co-Defendants U.S. Coachways (Coachways,) Transit Systems (Transit,) or Ofelia Rodriguez (Rodriguez.)  Under the first COA, Urciel Plaintiff alleged that Defendant negligently owned, operated, hired, supervised, trained, controlled, maintained, inspected, repaired the bus, or negligently failed to install safety devices.  Defendant provided testimony/facts from Maurice Venegas (Venegas,) Transit’s person most knowledgeable, and Rodriguez, as evidence in support of its position that Defendant did not own, operate, inspect, or control the bus either directly or vicariously.  (DSSF 56-57, 59, 66-68.)  Because evidence is presented that Defendant did not own, operate, inspect, or control the bus, Defendant met its initial burden to show that no triable issue of fact exists as to these claims.

Defendant presented facts to support its position that non-party American Fleet Services and third-party vendors maintained, inspected and/or repaired the bus.  (DSSF 63-65.)  Because evidence is presented that third-party entities maintained, inspected, or repaired the bus, there is no triable issue of fact as to these claims for negligence.

Defendant argued that there is no triable issue of fact as to Urciel Plaintiff’s claims related to the lack of seat belts.  With Defendant’s facts/evidence showing lack of ownership, there is no triable issue of fact that Defendant owed a duty to either provide seat belts or move any concerned Urciel Plaintiff onto another bus or warn passengers that the bus did not have seat belts.  Defendant submitted Vanegas’ testimony to show his understanding that regulations did not require seat belts on the bus at issue.  (Motion Exh. 7 at 8:9-11; 115:4-15; and Brinkerhoff Decl. pars. 6-7.)  Because Defendant’s evidence shows that there is no triable issue of fact as to ownership of the bus and no triable issue of fact as to an affirmative duty regarding the seat belts, Defendant has sufficiently met its initial burden of proof as to these claims.

As to Urciel Plaintiff’s first and second COA, Defendant again provided testimony/facts from Venegas and Rodriguez to show its position that Defendant did not hire, train, supervise, retain, employ, or enter any agency relationship with Coachways, Transit, or Rodriguez.  Rodriguez testified that she worked for Transit.  Defendant asserted that Transit was not employed by or an agent of Defendant.  Defendant’s facts/evidence support Defendant's position that it did not control Rodriguez or the buses. (DSSF 60-62, 69-71, 75-81, 87-89, 96-98, and 102-104.)  Based upon these facts, Defendant met its burden of proof to show that there is no triable issue of material fact as to Urciel Plaintiff’s first and second COAs’ claim that Defendant hired, trained, supervised, retained, employed, or entered any agency relationship with any Co-Defendants.

The Court notes that the issue of sale of the bus alleged in Urciel Plaintiff’s first COA was supported by testimony showing that Defendant was not involved in the sale/purchase of the bus and that the bus was purchased by Transit from a reseller.  (DSSF 59.)  As to the claim of negligent sale of the bus, Defendant met its initial burden to show that no triable issue of fact exists.

Specifically, in MSA Issue 3, Urciel Plaintiff’s first COA alleged that Defendant negligently manufactured, assembled, and sold the bus.  As to the claims for negligent manufacturing and assembly, Defendant submitted that Urciel Plaintiff alleged in the Complaint that North American Bus Industries, Inc (NABI) manufactured/assembled the bus.  (DSSF 56, 58, 83, 85.)  However, an unverified pleading is not admissible evidence.  As to Urciel Plaintiff’s specific allegation regarding manufacturing and assembly, Defendant did not meet its initial burden to show that no triable issue of fact exists.   Because Defendant did not meet its initial burden, the burden as to Urciel Plaintiff’s first COA did not shift to Urciel Plaintiff to show that a triable issue of fact exists regarding manufacturing or assembly.  Because Defendant did not meet its burden of proof as to all of Urciel Plaintiff’s claims in the first COA, there is grounds to deny Defendant’s MSJ as to Urciel Plaintiff’s Complaint and DENY Defendant’s MSA as to Issue 3.

Because Defendant did not meet its initial burden as to Issue 3, Defendant’s MSA as to Issue 3 is DENIED.

As to Issue 4, the burden shifts to Urciel Plaintiff to show that a triable issue of fact exists regarding hiring, training, supervising, retaining, employing, or entering any agency relationship with Coachways, Transit, or Rodriguez.

Urciel Plaintiff’s separate statement did not dispute most of Defendant’s facts in support of the issues of ownership, operation, management, entrustment, permission, control, driving, maintenance, repair, service, inspection, hiring, training, supervision, and retention.  However, as to claims based upon vicarious liability (i.e., employment and agency,) Urciel Plaintiff disputed Defendant’s denial of any agency relationship.  Urciel Plaintiff’s separate statement asserted disputes as to DSSF 89, 96, 98.  Urciel Plaintiff asserted that Rodriguez was Defendant’s employee through ostensible agency.  The essential elements of ostensible agency are: (1) a representation (or omission) by the principal (some act or neglect by the principal sought to be charged leading plaintiff reasonably to believe the third person was the principal's agent/employee);  (2) plaintiff's justifiable reliance thereon (plaintiff dealt with the supposed agent in the reasonable belief he or she (defendant) was authorized to act on the principal's behalf and was not negligent in relying upon the supposed agent's apparent authority);  (3) plaintiff's change of position or injury resulting from such reliance.  (Civ. Code sec. 2300; Markow v. Rosner (2016) 3 Cal.App.5th 1027, 1038; CACI 3709.)  However, the deposition testimony of Urciel Plaintiff to support these facts fails to present any evidence to show that Defendant made a representation to Urciel Plaintiff or that Urciel Plaintiff justifiably relied upon the representation.  None of Urciel Plaintiff’s deposition testimony presented any evidence that Urciel Plaintiff relied upon a flyer or any advertisement by Defendant.  (Urciel Plaintiff’s Additional Facts (UPAF) 109-110, 116.)  Further, Urciel Plaintiff’s reliance upon declarations from Co-Plaintiffs Isabel Lemus, Miguel Ibarra, and Arcelia Quinteros is unavailing to show a triable issue as to the first two elements for ostensible agency because representations made to Co-Plaintiffs are insufficient to show that representations were made to Urciel Plaintiff by Defendant.  Urciel Plaintiff’s arguments as to ostensible agency is insufficient to raise a triable issue of material fact as to vicarious liability.  Urciel Plaintiff’s arguments as to ostensible agency are insufficient to meet the burden to show the existence of a triable issue of fact.

Urciel Plaintiff argued that Defendant had a duty to provide safe transportation to and from the event and such duty was non-delegable to Co-Defendants.  However, a “duty to provide safe transport” is merely a generalized characterization of the specific duties addressed above.  Safe transportation of passengers is necessarily encompassed within the duty of care resulting from ownership, operation, management, entrustment, permission, control, driving, maintenance, repair, service, inspection, hiring, training, supervision, retention, providing safety devices, manufacture, assembly, and sale.  A claim of a “duty to provide safe transport” is insufficient without evidence of some duty of care (as noted above) to assert a viable duty of care.

Urciel Plaintiff argued that the duties of care at issue are non-delegable.  However, this is a non-sequitur argument because Urciel Plaintiff did not produce evidence sufficient to create a triable issue of fact as to whether Defendant had duties of care resulting from ownership, operation, management, entrustment, permission, control, driving, maintenance, repair, service, inspection, hiring, training, supervision, retention, providing safety devices, manufacture, assembly, and sale were applied to Defendant, either based upon direct liability or vicarious liability.

Defendant met its initial burden to show that no triable issue of fact exists as to the first and second COAs alleged by Urciel Plaintiff.  Urciel Plaintiff failed to meet her burden to show that a triable issue of facts exists.

Defendant’s MSA is GRANTED as to Issue 4.

Defendant’s MSJ as to the Urciel Complaint is MOOT.