Judge: Stephen P. Pfahler, Case: 22CHCV01332, Date: 2023-04-25 Tentative Ruling
Case Number: 22CHCV01332 Hearing Date: April 25, 2023 Dept: F49
Dept.
F-49
Date:
4-25-23
Case
#22CHCV01332
Trial Date: Not Set
DEMURRER
MOVING PARTY: Defendant, Nonprofits Insurance
Alliance of California
RESPONDING PARTY: Plaintiff, Homenetmen Western Region
RELIEF
REQUESTED
Demurrer
to the Complaint
·
1st
Cause of Action: Breach of Contract
·
2nd
Cause of Action: Breach of Covenant of Good Faith and Fair Dealing
·
3rd
Cause of Action: Unfair Business Practices Business and Professions Code 17200
·
4th
Cause of Action: Unjust Enrichment
·
5th
Cause of Action: Negligent Misrepresentation
·
6th
Cause of Action: Declaratory Relief
SUMMARY
OF ACTION
Plaintiff
Homenetmen Western Region contends defendant Nonprofits Insurance Alliance of
California wrongfully denied a claim related to business interruptions caused
by the Covid-19 pandemic and subsequent government orders from various
government agencies, including the City of Los Angeles and State of California.
On
December 18, 2022, Plaintiff filed a complaint for Breach of Contract, Breach
of Covenant of Good Faith and Fair Dealing, Unfair Business Practices Business
and Professions Code 17200, Unjust Enrichment, Negligent Misrepresentation, and
Declaratory Relief
RULING: Sustained with
Leave to Amend.
Request
for Judicial Notice: Denied.
The
court declines to take judicial notice of district and circuit court authority.
Defendant may present any and all authority in the points and authorities.
Defendant
Nonprofits Insurance Alliance of California submits a demurrer to the entire
complaint
on grounds of insufficient facts establishing coverage, and therefore failure
to state a claim. Plaintiff in opposition maintains all causes of action are
well pled. Defendant in reply reiterates the arguments in the demurrer,
including the viral and bacterial exclusion language, and the impact on all
individual causes of action.
A demurrer is an objection to a pleading, the grounds for
which are apparent from either the face of the complaint or a matter of which
the court may take judicial notice. (Code Civ. Proc., § 430.30, subd. (a); see
also Blank v. Kirwan (1985) 39 Cal.3d
311, 318.) The purpose of a demurrer is to challenge the sufficiency of a
pleading “by raising questions of law.” (Postley
v. Harvey (1984) 153 Cal.App.3d 280, 286.) “In the construction of a
pleading, for the purpose of determining its effect, its allegations must be
liberally construed, with a view to substantial justice between the parties.”
(Code Civ. Proc., § 452.) 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 applying these standards, the
court liberally construes the complaint to determine whether a cause of action
has been stated. (Picton v. Anderson Union High School Dist. (1996) 50 Cal.App.4th
726, 733.)
“A demurrer for
uncertainty is strictly construed, even where a complaint is in some respects
uncertain, because ambiguities can be clarified under modern discovery
procedures.” (Khoury v. Maly's of California, Inc. (1993) 14 Cal.App.4th 612, 616; Williams v. Beechnut Nutrition Corp. (1986) 185 Cal.App.3d
135, 139 [“[U]nder our liberal pleading rules,
where the complaint contains substantive factual allegations sufficiently
apprising defendant of the issues it is being asked to meet, a demurrer for
uncertainty should be overruled or plaintiff given leave to amend.]
1st
Cause of Action: Breach of Contract
Plaintiff
seeks to allege breach of contract based on the withholding of insurance
benefits under the business interruption clause of the policy. Plaintiff
acknowledges the Covid-19 pandemic outbreak during the relevant time frame, but
characterizes the interruption as a result of the government orders, rather
than the Covid-19 virus itself. [Comp., ¶¶ 3, 10-45.] The complaint articulates
a number of reasons for the alleged wrongful denial, including presentation of an
adhesion policy effectively preventing Plaintiff from the required coverage;
failure to disclose said exclusions; denial of any physical damage by the
insurer which would constitute a basis of coverage; and, lack of sufficient
investigation into the claim. [Comp., ¶¶ 46-70.] Plaintiff also cites to courts
in England and France as a basis of public policy support articulating the
wrongful denial claim. [Comp., ¶¶ 71-73.]
The operative
complaint incorporates a copy of the insurance policy. The court therefore
references the incorporated exhibit. Defendant directly cites to the
business interruption section, which specifically includes an exclusion for interruptions
caused by viral or bacterial outbreaks.
“‘While
insurance contracts have special features, they are still contracts to which
the ordinary rules of contractual interpretation apply.’ (Citation.) ‘The principles
governing the interpretation of insurance policies in California are well
settled. “Our goal in construing insurance contracts, as with contracts
generally, is to give effect to the parties' mutual intentions.”’ (Citation.) “‘Such
intent is to be inferred, if possible, solely from the written provisions of
the contract. (Citation.) The “clear and explicit” meaning of these provisions,
interpreted in their “ordinary and popular sense,’ unless ‘used by the parties
in a technical sense or a special meaning is given to them by usage’ (Citation),
controls judicial interpretation. (Citation.)’” (Citation) “‘If contractual
language is clear and explicit, it governs.’”
“‘If the
terms are ambiguous [i.e., susceptible of more than one reasonable
interpretation], we interpret them to protect “‘the objectively reasonable expectations
of the insured.’” (Citation.) This rule stems from the principle that “‘[i]f the terms
of a promise are in any respect ambiguous or uncertain, it must be interpreted
in the sense in which the promisor believed, at the time of making it, that the
promisee understood it.’” (Citation.) “‘Only if these rules do not resolve a claimed ambiguity
do we resort to the rule that ambiguities are to be resolved against the insurer....’ The
‘tie-breaker’ rule of construction against the insurer stems from the
recognition that the insurer generally drafted the policy and received premiums
to provide the agreed protection.” (Citation.) “[L]anguage in a contract must be interpreted as a
whole, and in the circumstances of the case, and cannot be found to be
ambiguous in the abstract.... Courts will not strain to create an ambiguity
where none exists.”
“‘The
insured has the burden of establishing that a claim, unless specifically
excluded, is within basic coverage, while the insurer has the burden of
establishing that a specific exclusion applies.’ (Citation.) The principles of
contractual interpretation, as applied to insurance policies ‘do not include using public
policy to redefine the scope of coverage.’”
(Inns-by-the-Sea v. California Mutual Ins.
Co. (2021) 71 Cal.App.5th 688, 697–698.)
The
existence of the viral bacterial exclusion remains undisputed. Defendant
specifically relies on a recent case regarding interpretation of a viral or
bacterial exclusion in support of the demurrer. “The virus exclusion expressly
bars coverage for all loss or damage caused by or resulting from ‘any virus,
bacterium or other micro-organism that induces or is capable of inducing
physical distress, illness or disease.’ Musso & Frank's allegation that its
losses were caused by the public health orders does not change the fact that
those orders were a response to the COVID-19 virus. (Citation.) The Ninth Circuit
agrees, observing that the complaint in that case did not allege an attenuated
causal chain between the virus and the insured's losses, and the insured did
not dispute the fact that the closure orders were due to COVID-19. (Citation.)” (Musso & Frank Grill
Co., Inc. v. Mitsui Sumitomo Ins. USA Inc.
(2022) 77 Cal.App.5th 753, 761.)
Plaintiff counters with an argument analogizing Covid-19 as
a means of causing physical loss or damage, in that the outbreak rendered the
property uninhabitable or unusable. Plaintiff cites a case involving E. Coli
bacteria. (Cooper v. Travelers Indem. Co.
of lllinois, Case No. C-01-2400-VRW, 2002 WL 32775680 at *1 (N.D. Ca. Nov.
4,2002),affd, 113 F. App'x 198 (9th Cir.2004) (applying California law).) The
court was unable to locate this case, and requests Plaintiff use official
citations, including proof that the subject case was actually published and
therefore citable. Plaintiff also cites to a case involving a landslide claim,
whereby the court found for the insureds based at least in part by the
displacement of the residents from the property from the underlying geologic
issues. (Strickland
v. Federal Ins. Co. (1988) 200 Cal.App.3d
792, 803.)
Plaintiff next analogizes the pandemic as a form of
trespass, in that the “invasion” of microscopic viral particles caused a
physical disruption to premises use and occupation. (Elton v. Anheuser-Busch
Beverage Group, Inc. (1996) 50 Cal.App.4th
1301, 1305; Civic Western Corp. v. Zila Industries, Inc. (1977) 66 Cal.App.3d 1, 16.) Plaintiff additionally cites
to out of state authorities, as well as other examples based on noxious fumes
and gases. Even without reviewing the E. Coli bacteria case, the court
appreciates the argument regarding the conflated approach presented in the
opposition physical (viral) disruption and the operative complaint pled government
shutdown allegations.
Regardless of the factual basis for the arguments, the
essence of the opposition relies on establishing the origin of the business disruption
constitutes an event fitting within the terms of the insurance policy. [Comp.,
¶¶ 31-45.] The Musso & Frank case
found efficient proximate cause doctrine applied. In considering the doctrine,
the court cited to prior decisions considering California laws and determined
government restrictions on business operations caused by the pandemic “remote”
as to a claim for business losses. Covid-19 related restrictions limited
operations to purposes “deemed essential,” but by no means demonstrated a
causal, physical displacement of all business. (Mudpie, Inc. v. Travelers Casualty Insurance
Company of America (9th Cir. 2021) 15
F.4th 885, 894.) Under this standard, and regardless of the attribution
describing the virus as a “physical” invader, the court finds no basis of a
valid, covered claim for business disruption around the viral bacterial
exclusion.
Plaintiff also cites to a “Civil Authority” basis of
coverage. [Comp., ¶¶ 63-69.] It’s not clear from the allegations in the
operative complaint, whether plaintiff relies on a different section of the
policy as basis of this coverage, or a form of establishing a wrongful exemption
under the bacterial and viral exclusion. Given the lack of appreciable clarity,
the court finds the argument subsumed within the efficient proximate cause
standard previously relied upon and discussed.
The court therefore finds
Plaintiff fails to establish a viable basis for breach of contract, as alleged.
Again, as discussed in the standard, it remains Plaintiff’s burden to establish
application of the terms. The court declines the invitation to make new public
policy declarations based on interpretation of public health proclamations and
the science behind the aerosol transmission of respiratory transmitted viruses.
The function of the trial court is to consider the operative terms of the
policy and facts alleged in interpreting potential coverage.
2nd
Cause of Action: Breach of Covenant of Good Faith and Fair Dealing
Given the lack of a valid contract claim, the court
also finds an invalid cause of action for bad faith. (McMillin Scripps North
Partnership v. Royal Ins. Co. (1993) 19
Cal.App.4th 1215, 1222; Careau & Co.
v. Security Pacific Business Credit, Inc. (1990)
222 Cal.App.3d 1371, 1395; Love v. Fire Ins. Exchange (1990)
221 Cal.App.3d 1136, 1153.)
3rd
Cause of Action: Unfair Business Practices Business and Professions Code 17200
“The UCL does not proscribe specific acts, but broadly
prohibits ‘any unlawful, unfair or fraudulent business act or practice and
unfair, deceptive, untrue or misleading advertising....’” [¶] “‘A private
plaintiff must make a twofold showing: he or she must demonstrate injury in
fact and a loss of money or property caused by unfair competition.’ (Citation.)” (Durell v. Sharp Healthcare (2010) 183 Cal.App.4th 1350, 1359.) Fact
specific pleading is not required in order to allege an unfair business
practice. (Quelimane Co. v. Stewart Title
Guaranty Co. (1998) 19 Cal.4th 26, 46–47.
An “unlawful” practice “means any
practices forbidden by law, be it civil or criminal, federal, state, or
municipal, statutory, regulatory, or court-made.… ‘Unfair’ simply means any
practice whose harm to the victim outweighs its benefits. (Citation.)
‘Fraudulent,’ as used in the statute, does not refer to the common law tort of
fraud but only requires a showing members of the public ‘“are likely to be
deceived.”’” (Saunders v. Superior
Court (1994) 27 Cal.App.4th 832, 838–839.) “[A]n
unfair business practice also means” the relied upon public policy provision is
“tethered” to a specific regulatory provisions. (Lueras v. BAC Home Loans Servicing, LP (2013) 221 Cal.App.4th 49, 81.)
To the extent the
complaint depends on the terms of the policy, the court finds no basis of
support for the subject cause of action in the current form of the complaint.
4th
Cause of Action: Unjust Enrichment
California no
longer recognizes unjust enrichment as a cause of action. Notwithstanding a party may state a claim in equity arising
in restitution. (Levine v. Blue Shield of California (2010) 189 Cal.App.4th
1117, 1138.) The court finds an insufficient basis for a claim of restitution
based on the underlying contractual dispute.
5th
Cause of Action: Negligent Misrepresentation
“Negligent misrepresentation is
a separate and distinct tort, a species of the tort of deceit. ‘Where the
defendant makes false statements, honestly believing that they are true, but
without reasonable ground for such belief, he may be liable for negligent misrepresentation, a
form of deceit.’” (Bily v. Arthur Young & Co. (1992) 3 Cal.4th 370, 407.) “The tort
of negligent misrepresentation does not require scienter or intent to
defraud. (Citation.) It encompasses ‘[t]he assertion, as a
fact, of that which is not true, by one who has no reasonable ground for
believing it to be true’ (Citation), and ‘[t]he positive assertion, in a manner
not warranted by the information of the person making it, of that which is not
true, though he believes it to be true’ (Citation)…’” (Small v. Fritz
Companies, Inc. (2003) 30 Cal.4th
167, 173–174.) Misrepresentations must be made about past or existing
fact. (Neu-Visions Sports, Inc. v.
Soren/McAdam/Bartells (2000) 86 Cal.App.4th 303, 309–310; Agricultural Ins. Co. v. Superior Court
(1999) 70 Cal.App.4th 385, 390.)
The
complaint insufficiently articulates the basis of this claim.
6th
Cause of Action: Declaratory Relief
Declaratory relief arises under Code of Civil Procedure
section 1060, which states in part:
“Any person interested under a contract, or who desires a
declaration of his or her rights or duties with respect to another, or in
respect to, in, over or upon property … may, in cases of actual controversy
relating to the legal rights and duties of the respective parties, bring an
original action or cross-complaint in the superior court for a declaration
of his or her rights and duties in the premises, including a determination of
any question of construction or validity arising under the instrument or
contract. He or she may ask for a declaration of rights or duties, either alone
or with other relief; and the court may make a binding declaration of these
rights or duties, whether or not further relief is or could be claimed at the
time. The declaration may be either affirmative or negative in form and effect,
and the declaration shall have the force of a final judgment. The declaration
may be had before there has been any breach of the obligation in respect to
which said declaration is sought.”
“‘[S]ection 1060 does not require a breach of contract
in order to obtain declaratory relief, only an ‘actual
controversy.’ Declaratory relief pursuant to this section has
frequently been used as a means of settling controversies between parties to a
contract regarding the nature of their contractual rights and obligations.’” (Osseous Technologies of America, Inc. v.
DiscoveryOrtho Partners LLC (2010) 191 Cal.App.4th 357, 365.)
Declaratory relief operates prospectively. (Id.
at p. 366.)
“[U]nder California rules, an actual controversy that is
currently active is required for such relief to be issued, and both
standing and ripeness are appropriate criteria in that determination.
(Citation.) One cannot analyze requested declaratory relief without evaluating
the nature of the rights and duties that plaintiff is asserting, which must
follow some recognized or cognizable legal theories, that are related to
subjects and requests for relief that are properly before the court.”
(Otay Land Co.v. Royal
Indemn. Co. (2008) 169 Cal.App.4th 556, 563.)
To
the extent the operative complaint relies on the terms of the policy for all
claims of declaratory relief, the court finds no basis of support.
The
demurrer is sustained with 30 days leave to amend. Plaintiffs may not add any new
or different causes of action, and may only add facts within the scope of the existing
insurance coverage dispute. (Harris v. Wachovia Mortgage,
FSB (2010)
185 Cal.App.4th 1018, 1023.) Any new causes of action added without leave from court
are subject to a motion to strike.
Defendant to give notice.