Judge: Steven A. Ellis, Case: 22STCV00628, Date: 2025-01-09 Tentative Ruling

Case Number: 22STCV00628    Hearing Date: January 9, 2025    Dept: 29

Ross v. Wyndham Hotels & Resorts, Inc.
22STCV00628
Defendants’ Motion to Dismiss for Failure to Prosecute

Tentative

The motion is denied as moot, as the moving parties have been dismissed.

Background

On January 6, 2022, Ashanti Marie Ross (“Plaintiff”) filed a complaint against Wyndham Hotels & Resorts, Inc. (“Wyndham”), Travel & Leisure Co. (“Travel & Leisure”), Days Inn by Wyndham Whittier Los Angeles (“Days Inn”), Tina Bera, and Does 1 through 20 for (1) battery, (2) negligence, (3) intentional infliction of emotional distress, (4) fraudulent concealment, (5) private nuisance, (6) public nuisance, and (7) breach of contract, all arising out of Plaintiff’s allegation that she was bitten by bed bugs during a stay from January 9 to 13, 2020, at the hotel located on Telegraph Road in Whittier.

On August 29, 2023, Wyndham and Travel & Leisure filed an answer.

On September 18, 2023, the Court, based on an oral request of Plaintiff’s counsel, dismissed Days Inn and Tina Bera, without prejudice.

On July 17, 2024, Plaintiff amended her complaint to name Bera Family Trust as Doe 1.

On August 30, 2024, the Court, based on the written request of Plaintiff, dismissed Wyndham and Travel & Leisure without prejudice.

On September 23, 2024, Plaintiff amended her complaint to name Rimal and Tuhina Bera Family Trust as Doe 2 and to name Tuhina Bera as Doe 3.

On November 1, 2024, Plaintiff filed a proof of service indicating that Days Inn was served by substituted service on October 30, 2024.

On December 6, 2024, Rimal and Tuhina Bera Family Trust filed an answer.

On December 6, 2024, Defendants Days Inn and Tina Bera (“Defendants”) filed this motion to dismiss for failure to serve the complaint within two years.

Plaintiff did not file a timely opposition. Plaintiff’s counsel filed a declaration (with an incomplete proof of service) on January 3, 2025.

Legal Standard

Code of Civil Procedure section 583.410, subdivision (a), states: “The court may in its discretion dismiss an action for delay in prosecution pursuant to this article on its own motion or on motion of the defendant if to do so appears to the court appropriate under the circumstances of the case.”¿ (Code Civ. Proc., § 583.410, subd. (a).) Subdivision (b) provides, ““Dismissal shall be pursuant to the procedure and in accordance with the criteria prescribed by rules adopted by the Judicial Council.” (Id., subd. (b).)¿ 

Code of Civil Procedure section 583.420, subdivision (a), states in part:¿ ¿ 

“(a) The court may not dismiss an action pursuant to this article for delay in prosecution except after one of the following conditions has occurred:¿ ¿ 

(1) Service is not made within two years after the action is commenced against the defendant.¿ ¿ 

(2) The action is not brought to trial within the following times:¿ ¿ 

(A) Three years after the action is commenced against the defendant unless otherwise prescribed by rule under subparagraph (B).¿ ¿ 

(B) Two years after the action is commenced against the defendant if the Judicial Council by rule adopted pursuant to Section 583.410 so prescribes for the court because of the condition of the court calendar or for other reasons affecting the conduct of litigation or the administration of justice.”¿ ¿ 

Moreover, California Rules of Court, rule 3.1340(a) provide that the court, on its own motion or on motion of the defendant, may dismiss an action under Code of Civil Procedure sections 583.410-583.430 for delay in prosecution if the action has not been brought to trial or conditionally settled within two years after the action was commenced against the defendant.¿  

In ruling on a motion to dismiss under section 583.410, the court must consider all matters relevant to a proper determination of the motion, including:¿ 

“(1) ¿The court's file in the case and the declarations and supporting data submitted by the parties and, where applicable, the availability of the moving party and other essential parties for service of process; 

(2) ¿The diligence in seeking to effect service of process; 

(3) ¿The extent to which the parties engaged in any settlement negotiations or discussions; 

(4) ¿The diligence of the parties in pursuing discovery or other pretrial proceedings, including any extraordinary relief sought by either party; 

(5) ¿The nature and complexity of the case; 

(6) ¿The law applicable to the case, including the pendency of other litigation under a common set of facts or determinative of the legal or factual issues in the case; 

(7) ¿The nature of any extensions of time or other delay attributable to either party; 

(8) ¿The condition of the court's calendar and the availability of an earlier trial date if the matter was ready for trial; 

(9) ¿Whether the interests of justice are best served by dismissal or trial of the case; and 

(10) ¿Any other fact or circumstance relevant to a fair determination of the issue.” 

(Cal. Rules of Court, rule 3.1342(e).)¿¿¿ 

Code of Civil Procedure section 583.130 provides courts with further guidance in ruling on a motion to dismiss:

“It is the policy of the state that a plaintiff shall proceed with reasonable diligence in the prosecution of an action but that all parties shall cooperate in bringing the action to trial or other disposition. Except as otherwise provided by statute or by rule of court adopted pursuant to statute, the policy favoring the right of parties to make stipulations in their own interests and the policy favoring trial or other disposition of an action on the merits are generally to be preferred over the policy that requires dismissal for failure to proceed with reasonable diligence in the prosecution of an action in construing the provisions of this chapter.”

¿ “The competing considerations to be evaluated are the policies of discouraging stale claims and compelling reasonable diligence balanced against the strong public policy which seeks to dispose of litigation on the merits rather than on procedural grounds.” (Van Keulen v. Cathay Pacific Airways, Ltd. (2008) 162 Cal.App.4th 122, 131.)¿ The policy of favoring trial on the merits, however, “only comes into play when a plaintiff makes a showing of some excusable delay.”¿ (Ibid.)¿¿

Discussion

Here, Defendants request that the Court dismiss them from this lawsuit based on Plaintiff’s failure to serve them for more than two years after the case was filed.

Defendants, however, have already been dismissed from the lawsuit. On September 18, 2023, the Court dismissed the Defendants at the request of Plaintiff.

It appears that Plaintiff may have served Defendants in October 2024. (Days Decl., ¶¶ 12-13.) But that service is improper and of no effect, as the Defendants were dismissed from the case more than one year earlier. Plaintiffs have made no attempt to vacate the dismissal or otherwise bring Defendants back into the suit.

Accordingly, the motion is denied as moot. Defendants have been dismissed from the lawsuit and remain dismissed from the lawsuit.

Conclusion

 

The Court DENIES AS MOOT Defendants’ motion to dismiss.

Moving Party is ordered to give notice.