Judge: Upinder S. Kalra, Case: 22STCV32532, Date: 2023-02-27 Tentative Ruling
Case Number: 22STCV32532 Hearing Date: February 27, 2023 Dept: 51
Tentative Ruling
Judge Upinder S.
Kalra, Department 51
HEARING DATE: February
27, 2023
CASE NAME: Lewis Cohen, et al. v. Starr Indemnity
& Liability Company
CASE NO.: 22STCV32532
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MOTION
TO STRIKE
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MOVING PARTY: Defendant Starr Indemnity &
Liability Company
RESPONDING PARTY(S): Plaintiffs Lewis Cohen and
Alejandra Cohen
REQUESTED RELIEF:
1. An
order striking portions of the Complaint that pertain to punitive damages.
TENTATIVE RULING:
1. Motion
to Strike is GRANTED, as to the portions of the Complaint that pertain to
punitive damages.
STATEMENT OF MATERIAL FACTS AND/OR PROCEEDINGS:
On October 4, 2022, Plaintiffs Lewis Cohen and Alejandra
Cohen (“Plaintiffs”) filed a complaint against Defendant Starr Indemnity &
Liability Company (“Defendant.”) The complaint alleged two causes of action:
(1) Breach of the Duty of Good Faith and Fair Dealing and (2) Breach of
Contract. Plaintiffs allege that when the purchased tickets for a cruise to
Antarctica, they purchased the APRIL Travel Protection – Pandemic Plus Plan.
During the cruise, Plaintiffs were mandated to quarantine due to a positive
Covid-19 test. Plaintiffs then submitted a Trip Interruption Claim with APRIL
Travel Protection. That claim was denied by Defendant Starr Indemnity &
Liability Company.
On November 23, 2022, Defendant filed the current Motion to
Strike. Plaintiffs’ Opposition was filed on Feburary 10, 2023. Defendant’s
Reply was filed on February 17, 2023.
LEGAL STANDARD
Motion to Strike
The court may, upon a motion, or at
any time in its discretion, and upon terms it deems proper, strike any
irrelevant, false, or improper matter inserted in any pleading. (Code Civ.
Proc., § 436(a).) The court may also strike all or any part of any pleading not
drawn or filed in conformity with the laws of this state, a court rule, or an
order of the court. (Id., § 436(b).)
The grounds for moving to strike must appear on the face of the pleading or by
way of judicial notice. (Id. § 437.) “When
the defect which justifies striking a complaint is capable of cure, the court
should allow leave to amend.” (Vaccaro v.
Kaiman (1998) 63 Cal.App.4th 761, 768.)
Meet and Confer:
Prior to filing a motion to strike,
the moving party is required to satisfy their meet and confer obligations
pursuant to Code of Civ. Proc. §435.5, and demonstrate that they so satisfied
their meet and confer obligation by submitting a declaration pursuant to Code
of Civ. Proc. §435.5(a)(2). The Declaration of Joshua D.
Mountain indicates that the parties emailed about punitive damages on November
10, 2022. Thereafter, on November 15, 2022, the parties met and conferred
telephonically. The parties were unable to reach a conclusion. (Dec. Mountain ¶
5-6.)
ANALYSIS:
Defendant moves to strike various
portions of the complaint. Specifically, Defendant moves to strike requests for
exemplary or punitive damages. The portions include:
·
Page 8, paragraph 6, lines 7-14
·
Page 8, paragraph 7, lines 15-20
·
Page 9, Prayer for Relief, paragraph 3,
lines 24-25
Defendant argues that Plaintiffs’
claims fail to support punitive damages. The facts as alleged in Plaintiffs’’
complaint do not support the heightened standard for punitive damages and do
not plead any conduct that would be oppressive, malicious, or fraudulent. Additionally,
the allegations are conclusory and do not support punitive damages because
under Civil Code § 3294, the allegations, including the pleading stage, must be
allege specific facts. Here, Defendant argues that the claims for punitive
damages are based on “conclusory statements unsupported by the remaining
allegations in the complaint,” stating that Defendant’s conduct was “highly reprehensible.”
(Motion 8: 12-15.) Lastly, a prayer for punitive damages applies in exceptional
circumstances and Plaintiffs’ complaint does not allege specific facts, only
boilerplate conclusions.
Plaintiffs
argue that the facts as alleged in the complaint are sufficient to support a
claim for punitive damages. The complaint alleges that Defendant’s conduct was
dishonest and despicable and deprived Plaintiffs of the benefit of the
insurance coverage that they purchased. Plaintiffs argue that read as a whole,
the complaint alleges that Defendant engaged in wrongful conduct – “depriving
Plaintiffs of the benefits due to them under the Policy” and therefore support
a claim for punitive damages. (Opp. 8: 12-16.)
To obtain punitive damages, a plaintiff
must plead sufficient facts in
support of punitive damages. (See Hilliard v. A.H. Robins Co. (1983) 148 Cal.App.3d 374,
391-92.) In addition, punitive damages are allowed only where “it is
proven by clear and convincing evidence that the defendant has been guilty of
oppression, fraud, or malice.” (Civ. Code, § 3294, subd. (a).)
Courts have viewed despicable conduct as conduct “so vile, base, contemptible,
miserable, wretched or loathsome that it would be looked down upon and despised
by ordinary decent people. (Scott v.
Phoenix Schools, Inc., (2009) 175 Cal.App.4th 702, 715.) Further, Civil
Code § 3294(c) provides the definition of malice, oppression, and fraud. Malice
is “conduct which is intended by the defendant to cause injury to the plaintiff
or despicable conduct which is carried on by the defendant with a willful and
conscious disregard of the rights or safety of others.” Oppression is
“despicable conduct that subjects a person to cruel and unjust hardship in
conscious disregard of that person's rights.” Fraud is “an intentional
misrepresentation, deceit, or concealment of a material fact known to the
defendant with the intention on the part of the defendant of thereby depriving
a person of property or legal rights or otherwise causing injury.”
After a review of the complaint,
the Court finds that the allegations do not allege specific facts supporting
punitive damages, but rather state conclusions. Moreover, the allegations in
the Complaint are based on the denial of coverage under an insurance policy.
This is not the type of conduct that would be viewed in the abstract as
malicious, fraudulent, or oppressive. Stated otherwise, even if a reasonable
person viewed the denial of an insurance policy as very wrong, these facts do
not rise to the type of conduct that would “so vile, base contemptible,
miserable, wretched or loathsome.” (Scott,
supra, 175 Cal.App.4th at
p.715.)
Therefore,
the Motion to Strike is GRANTED, as to the portions of the Complaint that
relate to punitive damages.
CONCLUSION:
For the foregoing reasons, the
Court decides the pending motion as follows:
Motion
to Strike is GRANTED.
Moving party is to give notice.
IT IS SO ORDERED.
Dated: February 27, 2023 __________________________________ Upinder
S. Kalra
Judge
of the Superior Court