Judge: Steven A. Ellis, Case: 22STCV00771, Date: 2025-05-05 Tentative Ruling

Case Number: 22STCV00771    Hearing Date: May 5, 2025    Dept: 29

Rindone v. Angel Plumbing Co.
22STCV00771
Motion to Quash Service of Summons filed by Specially Appearing Defendant Angel Plumbing Co.
Motion to Dismiss for Failure to Serve Summons within 3 years filed by Specially Appearing Defendant Angel Plumbing Co.

Tentative

The Court will call this matter.

Background

On January 7, 2022, Girolamo Rindone (“Plaintiff”) filed a complaint against Angel Plumbing Co. (“APC”), Pedro Alberto Galeas (“Galeas”), and Does 1 through 100 for motor vehicle negligence and general negligence arising out of an accident on January 8, 2020 on Benedict Canyon Drive in Beverly Hills.

On November 17, 2023, counsel purporting to represent Defendant Galeas brought a motion to quash service of the summons. The Court denied the motion, without prejudice, as it was reported to the Court that Defendant Galeas had died in February 2021, and it was not clear what authority (if any) counsel had to act on behalf of the decedent. As the Court explained at that time:

“Both Plaintiff and the insurer purporting to act on behalf of Defendant Galeas have statutory options regarding how to proceed in a procedurally proper manner. As long as they choose not to pursue them, however, the Court has a very limited ability to issue an order granting any motion.”

(Minute Order dated April 9, 2024.)

On April 1, 2025, Plaintiff filed a proof of personal service as to APC.

Currently before the Court and set for hearing on May 5, 2025, are two motions.

First, on April 4, 2025, APC filed a motion to quash service of summons.

Second, on April 9, 2025, APC filed a motion to dismiss.

Plaintiff filed an opposition to the motion to dismiss on April 22. APC filed a reply on April 24.

Plaintiff did not file an opposition to the motion to quash.

Legal Standard

Motion to Quash

The various methods for service of a summons and complaint are set forth in Code of Civil Procedure sections 415.10 through 416.90.

“When a defendant challenges the court’s personal jurisdiction on the ground of improper service of process the burden is on the plaintiff to prove the existence of jurisdiction by proving, inter alia, the facts requisite to an effective service.” (Summers v. McClanahan (2006) 140 Cal.App.4th 403, 413.) Although the filing of a proof of service by a registered process server creates a rebuttable presumption that service was proper (see Evid. Code § 647), that presumption may be rebutted by contrary evidence. (See, e.g., Fernandes v. Singh (2017) 16 Cal.App.5th 932, 941 fn.6.) 

In ruling on a motion to quash service of summons, the trial judge acts as the finder of fact and can resolve any conflicts in the evidence. (Kroopf v. Guffey (1986) 183 Cal.App.3d 1351, 1356.)

 

If service of summons is not properly and validly effectuated by one or more of the approved methods, California courts lack personal jurisdiction over the defendants, and any judicial actions taken without such service violates principles of fundamental due process and is therefore void. (Cnty. of San Diego v. Gorham (2010) 186 Cal.App.4th 1215, 1231.)

Motion to Dismiss

Code of Civil Procedure section 583.210 requires service of the summons and complaint within three years of filing:

“The summons and complaint shall be served upon a defendant within three years after the action is commenced against the defendant.  For the purpose of this subdivision, an action is commenced at the time the complaint is filed.”

(Code Civ. Proc., § 583.210, subd. (a).)

Code of Civil Procedure section 583.250 provides for mandatory dismissal if the summons and complaint are not served within three years of filing:

“(a) If service is not made in an action within the time prescribed in this article:

(1) The action shall not be further prosecuted and no further proceedings shall be held in the action.

(2) The action shall be dismissed by the court on its own motion or on motion of any person interested in the action, whether named as a party or not, after notice to the parties.

(b) The requirements of this article are mandatory and are not subject to extension, excuse, or exception except as expressly provided by statute.”

(Code Civ. Proc., § 583.250.)

The statutory exceptions to this mandatory dismissal rule are set forth in Code of Civil Procedure section 583.240:

“In computing the time within which service must be made pursuant to this article, there shall be excluded the time during which any of the following conditions existed:

(a) The defendant was not amenable to the process of the court.

(b) The prosecution of the action or proceedings in the action was stayed and the stay affected service.

(c) The validity of service was the subject of litigation by the parties.

(d) Service, for any other reason, was impossible, impracticable, or futile due to causes beyond the plaintiff’s control. Failure to discover relevant facts or evidence is not a cause beyond the plaintiff’s control for the purpose of this subdivision.”

(Code Civ. Proc., § 583.240.)

Discussion

The Court has received information that the business entity APC has been suspended. (Tissot Decl., Exh. D.) A suspended corporation lacks the capacity to sue and, if sued, it lacks the capacity to defend. Nor may an attorney represent a suspended corporation in court and seek any relief on its behalf.

The Court will call this matter and inquire whether APC is a suspended corporation. If so, then: (1) both motions will be placed off calendar without prejudice (subject to potential renewal if APC resolves its suspension and returns to good standing); and (2) the Court will set an Order to Show Cause as to why the entire action should not be dismissed under Code of Civil Procedure sections 583.210 and 583.250.

Motion to Quash

On April 1, 2025, Plaintiff filed a proof of service. According to the proof, APC was served by personal delivery of the summons and complaint to an individual named “Chris Munos” at an address identified as “Isabel Munoz – State Farm Insurance Agent, 3804 W. Burbank Boulevard, Suite A, Burbank, CA 91505.”

In support of the motion, APC filed a declaration from Angel Muriedas, the owner of APC. (Muriedas Decl., ¶ 2.) Mr. Muriedas testifies that neither Chris Munoz nor Isabel Munoz is an authorized representative of APC and that neither is employed by or associated in any way with APC. (Id., ¶ 3.) Moreover, the service was effected at an address that was a previous location for APC, but APC stopped doing business at that location in 2006. (Id., ¶¶ 4-5.) APC has not received any documents from any person or entity on behalf of Plaintiff. (Id., ¶ 6.)

The Court’s tentative ruling is to credit the declaration of Mr. Muriedas.

The burden is on Plaintiff to show that service was proper. The Court’s tentative ruling is that Plaintiff has not met that burden, and that the motion to quash is granted.

The Court will call this matter.

Motion to Dismiss

APC seeks to dismiss Plaintiff’s complaint as to it, Defendant Pedro Alberto Galeas, and Does 1 to 100 under Code of Civil Procedure section 583.210 as service was not made within three years of filing Plaintiff’s complaint.

The Court will call this matter.

The Court’s tentative ruling is to deny the motion as to Defendant Galeas, who died in February 2021 (after the accident but before the complaint was filed). Although Plaintiff has procedurally proper statutory options regarding how to proceed with the cause of action against a decedent, Plaintiff appears not to have done so. The Court also notes that there was a substantial period of time in which the validity of service as to Defendant Galeas was the subject of litigation by the parties.

The Court’s tentative ruling is to grant the remainder of the motion. The defendants were not served during the three-year period after the filing of the complaint, and none of the statutory exclusions set forth in Code of Civil Procedure section 583.240 applies.

Conclusion

The Court will call this matter.





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