Judge: Stuart M. Rice, Case: 21STCV20095, Date: 2024-12-20 Tentative Ruling




Case Number: 21STCV20095    Hearing Date: December 20, 2024    Dept: 1

Moving Party:             Plaintiff Jay Aliff

Responding Party:      Defendant California Fair Plan Association

Ruling:                        Motion for class certification denied.

 

This is a proposed class action.  Plaintiff Jay Aliff (Plaintiff) alleges that defendant California Fair Plan Association (Defendant) issues property insurance policies whose fire coverage is unlawfully restrictive with respect to claims for smoke damage.  Plaintiff now moves to certify the following class:

 

All persons or entities insured under a Fair Plan policy initiated or renewed after July 1, 2017, which supplies BASIC PROPERTY INSURANCE, as defined in Insurance Code § 10091(c), who made claims, and whose claims Fair Plan denied or partially denied in reliance in whole or in part on (a) the policy’s definition of “direct physical loss” and/or (b) the policy’s “Smoke Damage” provision.

 

 

Procedural History

 

Plaintiff filed this action on May 27, 2021.  On October 21, 2022, Defendant demurred to and moved to strike portions of Plaintiff’s operative Second Amended Complaint (the SAC), which the Court overruled on December 16, 2022.  Specifically, Defendant demurred to Plaintiff’s class allegations, and the Court expressed concern that Plaintiff might face obstacles to obtaining class certification based on the cases of Basurco v. 21st Century Ins. Co. (2003) 108 Cal.App.4th 110 (Basurco) and Newell v. State Farm Gen. Ins. Co. (2004) 118 Cal.App.4th 1094 (Newell), in which similar claims based on earthquake coverage had been found inappropriate for class treatment.  Nonetheless, the Court overruled that demurrer, holding that in light of the strong judicial preference for deferring questions of class sufficiency to class certification, this was a matter better addressed at a later stage.  Plaintiff then requested dismissal of the causes of action for breach of the insurance policy and bad faith, which the Court entered on March 15, 2024.  The only remaining causes of action in the SAC are for declaratory relief and unfair business practices (Bus. & Prof. Code § 17200 et seq.).  This motion followed. 

 

Legal Standards

 

California Code of Civil Procedure Section 382 permits the Court to certify a class action when the moving party shows the superiority of pursuing the representative action on behalf of a sufficiently numerous and ascertainable class with a well-defined community of interest. (See, e.g., Brinker Rest. Corp. v. Superior Court (2012) 53 Cal.4th 1004, 1021 (Brinker).) The community of interest requirement entails showing that: (1) predominant common questions of law or fact exist; (2) the class representatives have claims or defenses typical of absent class members; and (3) the class representatives and their counsel can adequately represent the interests of the class. (Ibid.)  Because class certification requires that a “substantial benefit will result both to the litigants and to the court[,]” the movant must also show that a class action is “superior to other available methods for the fair and efficient adjudication of the controversy.”  (Dean Witter Reynolds, Inc. v. Superior Court (1989) 211 Cal.App.3d 758, 772-773.) 

 

California courts consider “pattern and practice evidence, statistical evidence, sampling evidence, expert testimony, and other indicators of a defendant’s centralized practices in order to evaluate whether common behavior towards similarly situated plaintiffs makes class certification appropriate.” (Sav-On Drug Stores, Inc. v. Superior Court (2004) 34 Cal.4th 319, 333 (Sav-On Drug).) The burden is on the party seeking class certification to establish each of the class prerequisites through substantial evidence. Id. at 327. When determining certification, the Court examines all presented evidence “under the prism of [the] plaintiff’s theory of recovery.” (Dep’t of Fish & Game v. Superior Court (2011) 197 Cal.App.4th 1323, 1349.)

 

When weighing the evidence, the Court does not evaluate the merits of the asserted claims. (Linder v. Thrifty Oil Co. (2000) 23 Cal.4th 429, 439-440.) Rather, the primary question on certification is “whether the theory of recovery advanced by the proponents of certification is, as an analytical matter, likely to prove amenable to class treatment.” (Sav-On Drugs, supra, 34 Cal.4th at 327.) Nevertheless, “when the merits of the claim are enmeshed with class action requirements, the trial court must consider evidence bearing on the factual elements necessary to determine whether to certify the class.” (Bartold v. Glendale Fed. Bank (2000) 81 Cal.App.4th 816, 829; see also Brinker, supra, 53 Cal.4th at 1023-1024 [“In many instances, whether class certification is appropriate or inappropriate may be determined irrespective of which party is correct. In such circumstances, it is not an abuse of discretion to postpone resolution of the disputed issue.”])

 

Request for Judicial Notice

 

Defendant’s Request

 

Defendant requests judicial notice of an order entered May 1, 2024 in Mapel v. California FAIR Plan Association, Santa Cruz Case No. 22CV00631.  This is a court record subject to judicial notice under Evid. Code § 452(d), and the Court grants judicial notice of it.

 

Plaintiff’s Request

 

Plaintiff requests judicial notice of the following:

 

A.    The Second Amended Complaint in this matter.  This is a court record under Evid. Code § 452(d) and the Court grants judicial notice of it.

B.     The California Department of Insurance’s Market Conduct Examination of California FAIR Plan Association, adopted May 25, 2022.  This evidences official acts of an executive department of the State of California subject to judicial notice under Evid. Code § 452(c), and the Court grants judicial notice of it, although not for the truth of its contents.

C.     A letter from the General Counsel of the Department of Insurance to Defendant dated January 4, 2021.  This evidences an official act of an executive department of the State of California, and the Court grants judicial notice of it, although not for the truth of its contents.

 

Discussion

 

Given the arguments raised by the parties, the Court will address the class certification requirements of adequacy and superiority first. 

 

I.                   Adequacy

II.                Superiority of Class Treatment

 

Defendant contends that Plaintiff is an inadequate class representative, because he has dismissed his claims for damages and request for restitution, and if he obtains class certification, a judgment on those claims will foreclose class members from seeking their own suits for damages.  Defendant’s argument is grounded in the “primary rights” doctrine, which bears discussion.

 

Under the “primary right” theory of pleading, “a ‘cause of action’ is comprised of a ‘primary right’ of the plaintiff, a corresponding ‘primary duty’ of the defendant, and a wrongful act by the defendant constituting a breach of that duty.”  (Crowley v. Katleman (1994) 8 Cal.4th 666, 681 (Crowley).)  The primary right “must therefore be distinguished from the legal theory on which liability for that injury is premised: ‘Even where there are multiple legal theories upon which recovery might be predicated, one injury gives rise to only one claim for relief.’ [Citation.]” (Id., at 681-682.) 

 

The primary right theory has a fairly narrow field of application. It is invoked most often when a plaintiff attempts to divide a primary right and enforce it in two suits. The theory prevents this result by either of two means: (1) if the first suit is still pending when the second is filed, the defendant in the second suit may plead that fact in abatement [citations]; or (2) if the first suit has terminated in a judgment on the merits adverse to the plaintiff, the defendant in the second suit may set up that judgment as a bar under the principles of res judicata [citation]. The latter application of the primary right theory appears to be most common: numerous cases hold that when there is only one primary right an adverse judgment in the first suit is a bar even though the second suit is based on a different theory [citation] or seeks a different remedy [citation].

(Crowley, supra, 8 Cal.4th at 682.)

 

Plaintiff’s entire SAC, including the dismissed causes of action, is premised on the same invasion of a primary right: Defendant’s reliance on allegedly invalid provisions of its property insurance policy to deny insurance claims.  Irrespective of whether that conduct is characterized as an unfair business practice under the Unfair Competition Law (UCL, Bus. & Prof. Code § 17200 et seq.), or a breach of the policy itself, or of the implied covenant of good faith and fair dealing inherent in that policy, and irrespective of what remedy Plaintiff seeks for that conduct (damages, restitution, injunction, declaratory relief), it is but a single primary right under the Crowley approach. 

 

This raises significant problems for class treatment, because a judgment in the action would be preclusive on class members.  (See Villacres v. ABM Industries, Inc. (2010) 189 Cal.App.4th 562, 591-592 [judgment in certified class action is preclusive on class members].)  City of San Jose v. Superior Court (Lands Unlimited) (1974) 12 Cal.3d 447 (City of San Jose) is instructive.  There, the plaintiffs sued on behalf of a class of property owners under the flight pattern of San Jose Airport, but sought only nuisance damages for diminution in value of their property, exclusive of all other available damages.  (Id. at 464.)  The Court of Appeal reversed the Trial Court’s grant of class certification, holding that the plaintiffs

 

inadequately represent the alleged class because they fail to raise claims reasonably expected to be raised by the members of the class and thus pursue a course which, even should the litigation be resolved in favor of the class, would deprive class members of many elements of damage.

[¶…¶]

It is clear under California law a party cannot, as a general rule, split a single cause of action because the first judgment bars recovery in a second suit on the same cause. [Citation.] As a result, by seeking damages only for diminution in market value, plaintiffs would effectually be waiving, on behalf of the hundreds of class members, any possible recovery of potentially substantial damages—present or future. This they may not do.

(Ibid.)

 

The Court’s ruling was grounded in the fiduciary duty of the class representative to protect the interests of absent class members:

 

To fulfill this fiduciary duty the representative plaintiff must raise those claims ‘reasonably expected to be raised by the members of the class.’ [Citation.] Clearly, under the facts alleged here the members of the class would reasonably be expected to seek recovery of damages beyond mere diminution in market values. Thus, by certifying this class, the trial court sanctioned a clear violation of plaintiffs' fiduciary duty.

(Ibid.)

 

Plaintiff’s class certification motion poses the same danger.  A class member would expect to recover damages or other monetary relief for Defendant’s alleged conduct, which deprived them of coverage for their losses.  Plaintiff clearly recognizes this, as his proposed certification purports to preserve class members’ ability to bring individual claims.  (See Plaintiff’s Memorandum, pp. 22-23.)  But for the reasons discussed above, there is a very real possibility that class members would be barred by res judicata if they sought to do so, under a primary rights analysis. 

 

Plaintiff’s reply brief contains no discussion of the primary rights issue at all.  Rather, Plaintiff cites Lebrilla v. Farmers Group, Inc. (2004) 119 Cal.App.4th 1070 (Lebrilla) and Hicks v. Kaufman and Broad Home Corp. (2001) 89 Cal.App.4th 908 (Hicks) as supporting his adequacy.  Lebrilla is of no assistance.  There, the Court expressly held that the failure to assert additional claims on behalf of the class was harmless, because the defendant “fail[ed] to point out what the class would have to gain by this additional claim, in addition to the ones already alleged.”  (Lebrilla, supra, 119 Cal.App.4th at 1089.)  Unlike the case in City of San Jose, exclusion of the claim does not waive a crucial or unique category of damages.”  (Ibid.)  That is the case here.

 

Hicks presents an interesting alternative, albeit a seemingly untested one.  In Hicks, the plaintiffs sued a homebuilder and the manufacturer of a mesh used in concrete foundation slabs which caused them to suffer larger and more damaging cracks, but sought only repair or replacement costs, not consequential damages for personal injury or property damage caused by the cracks.  (Hicks, supra, 90 Cal.App.4th at 912-913.)  The Court of Appeal reversed a denial of class certification on grounds not relevant here.  (Id. at 913.)  The manufacturer argued that the denial could be sustained on independent grounds, namely that the plaintiffs were not adequate representatives because they had failed to protect the interests of class members who had suffered consequential damages.  (Id. at 924-925.)  Held the Court of Appeal:

 

In our view, it is premature to sound the death knell for this class action based on inadequacy of representation.

[¶…¶]

There are several ways in which the trial court could certify a class without waiving the right of class members with property damage to recover for that damage. For example, the trial court could limit the class issues to liability for breach of warranty vel non and allow each class member to use that judgment as the basis for an individual action to recover damages for the breach. Alternatively, the court could divide the class into subclasses: those asserting only economic damages and those asserting economic damages and property damage. …Another possibility is for the trial court to use the class notice procedure to give those class members with property damage the opportunity to opt out of the class. This was the solution adopted by the court in Anthony when faced with the same argument raised by SI in the present case.

(Id. at 925-926, footnotes omitted.)

 

There is a notable distinction between this case and Hicks, which is that every putative class member in this case would have suffered monetary damages from the denial of their claim.  A liability-only class has superficial appeal, but the Court has been unable to find any example of this having actually been done, even in cases more factually akin to the Hicks case.  In Evans v. Lasco Bathware, Inc. (2009) 178 Cal.App.4th 1417, the Court of Appeal affirmed a Trial Court’s refusal to certify a Hicks-style liability-only class, because the plaintiffs at bar would still need to prove causation to show an entitlement to relief.  (Id. at 1435.)  The Evans court specifically described Hicks’ suggestion of a liability-only class as dicta.  (Ibid.) 

 

This brings the Court to superiority, a related component of the certification analysis.  Under these circumstances, it does not appear that a class action would be superior to an individual action. 

 

In deciding whether a class action would be superior to individual lawsuits, “the court will usually consider [four factors]: [¶] [ (1) ] The interest of each member in controlling his or her own case personally; [¶] [ (2) ] The difficulties, if any, that are likely to be encountered in managing a class action; [¶] [ (3) ] The nature and extent of any litigation by individual class members already in progress involving the same controversy; [and][¶] [ (4) ] The desirability of consolidating all claims in a single action before a single court.”

(Basurco, supra, 108 Cal.App.4th at 121, citing Weil & Brown, Cal. Practice Guide: Civil Procedure Before Trial (The Rutter Group 2002).)

 

As held in Basurco and Newell, plaintiffs in home insurance cases such as these have a “strong interest in controlling their own cases[.]”  (Basurco, supra, 108 Cal.App.4th at 121; accord Newell, supra, 118 Cal.App.4th at 1104.)  It is true that under a liability-only Hicks approach, there would not be individualized proof issues under the second factor.  (See Basurco, supra, 108 Cal.App.4th at 121 [“a class action would be extremely difficult to manage because individual issues predominate over common questions of law and fact.”]; Newell, supra, 118 Cal.App.4th at 1105 [same].)  But the third factor, seemingly concerned with avoiding interference in “litigation by individual class members already in progress involving the same controversy[,]” is even more threatened by the preclusion issue described above.  If the mere superfluity of a class action in the face of individual lawsuits is worthy of consideration (see Basurco, supra, 108 Cal.App.4th at 121 [287 separate actions]), then the Court must take even more seriously the potential preclusive effect of a class action on individual litigation. 

 

Finally, it is undesirable, and seemingly unnecessary, to consolidate all claims in a single action.  There are no claims for money damages in this case, only injunctive and declaratory relief.  The declaration Plaintiff seeks concerning Defendant’s policy would ostensibly be binding on Defendant’s interpretation of its policy going forward, and the UCL empowers the Court to “make such orders or judgments…as may be necessary to prevent the use or employment by any person of any practice which constitutes unfair competition[.]”  (Bus. & Prof. Code § 17203.)  Meanwhile, class certification threatens preclusion of putative class members’ potential claims for damages as discussed above.  Indeed, it appears that there are at least four individual cases currently pending in which putative class members are seeking damages arising from Defendant’s policies.  Class treatment would therefore add nothing, and for absent class members, threaten everything. 

 

For the foregoing reasons, the elements of adequacy and superiority are both lacking and therefore the motion must be denied.

 

III.             Ascertainability

IV.             Numerosity

V.                Existence of Common Questions

VI.             Typicality

 

Although there are colorable arguments on both sides as to the other requirements for class certification, the failure of both the adequacy and superiority requirements renders it unnecessary for the Court to address them.  The Court will instead deny the motion.

 

Conclusion

 

For the foregoing reasons, the motion for class certification is denied.  Defendant to give notice.