Judge: Virginia Keeny, Case: 22VECV02514, Date: 2023-03-27 Tentative Ruling

Case Number: 22VECV02514    Hearing Date: March 27, 2023    Dept: W

BRYAN GUINO v. AMERICAN HONDA MOTOR CO., INC.

 

Demurrer to complaint

 

Date of Hearing:        March 27, 2023                                 Trial Date:       None Set.

Department:              W                                                        Case No.:        22VECV02514

 

Moving Party:            Defendant American Honda Motor Co.

Responding Party:     Plaintiff Bryan Guino

Meet and Confer:      Yes. (LaCour Decl. ¶2.)

 

BACKGROUND

 

This is a lemon law action which arises from Plaintiff’s lease of a 2020 Honda Accord. On December 21, 2022, Plaintiff filed a complaint against Defendant American Honda Motor Co. asserting causes of action for Violation of Song-Beverly Act and Fraudulent Inducement – Concealment. Plaintiff alleges their vehicle had a sensing defect, which Defendant knew about and concealed.

 

[Tentative] Ruling

 

Defendant American Honda Motor Co., Inc.’s Demurrer is SUSTAINED WITH LEAVE TO AMEND.

 

REQUEST FOR JUDICIAL NOTICE

 

In opposition, Plaintiff requests this court take judicial notice of the second amended complaint filed in Dhital v Nissan North America, Inc., No. RG19009260 in Alameda County (Exh. 1.)

 

Defendant opposes the request for judicial notice on the grounds a petition for review of the matter was granted February 1, 2023. Defendant states as noted by California Rules of Court Rule 8.1115(e)(1) “While review is pending. Pending review and filing of the Supreme Court's opinion, unless otherwise ordered by the Supreme Court under (3), a published opinion of a Court of Appeal in the matter has no binding or precedential effect, and may be cited for potentially persuasive value only.”

 

The court grants Plaintiff’s request for judicial notice. The court notes it has been called to the court’s attention that the case is currently pending review.

 

DISCUSSION

 

Defendant American Honda Motor Co., Inc. (“AHM”) demur to the Second Cause of Action for Fraudulent Inducement – Concealment on the grounds Plaintiff’s Second Cause of Action fails to state facts sufficient to constitute a fraud cause of action against AHM.

 

The elements of a claim for fraudulent concealment are: “(1) concealment or suppression of a material fact; (2) by a defendant with a duty to disclose that fact to the plaintiff; (3) the defendant intended to defraud the plaintiff by intentionally concealing or suppressing the fact; (4) the plaintiff was unaware of the fact and would not have acted as he or she did if she had known of the concealed or suppressed fact; and (5) plaintiff sustained damages as a result of the concealment or suppression of the fact.” (Hambrick v. Healthcare Partners Medical Group, Inc.¿(2015) 238 Cal.App.4th 124, 162.) As it is a species of fraud and deceit, such claim must be plead with specificity. (Lazar v. Superior Court (1996) 12 Cal.4th 631, 645 (specificity means pleading the who, where, when, what, and how).) But this rule for fraud by concealment, unlike fraud by an affirmative misrepresentation, must be applied differently in the case of non-disclosure because it is difficult to allege “who” or “how” or “by what means” something was not disclosed or “when” or “where” a statement was not made. (Alfaro v. Community Housing Imp. System & Planning Ass’n, Inc. (2009) 171 Cal.App.4th 1356, 1384.)  Because of the nature of such fraud and the fact such facts supporting concealment are more likely to be known by defendant, less particularity is required.  (Id.)

 

Defendant first demurs to the second cause of action on the grounds Plaintiff failed to plead that AHM concealed or suppressed a material fact. Specifically, Defendant AHM contends Plaintiff does not plead with specificity what representations were made and merely alleging that AHM omitted facts about an alleged Sensing Defect in its general advertisements to an unknown audience cannot establish: (1) knowledge of a particular defect in a particular vehicle, or (2) intent to conceal this particular knowledge from this particular Plaintiff.

 

The court disagrees. Plaintiff alleges Defendant AHM knew about the safety hazard posed by the Honda Sensing Defect before the sale of vehicles from pre-market testing, consumer complaints to the National Highway Traffic Safety Administration, consumer complaints made directly to AHM and its dealers, testing conducted in response to those complaints, high failure rates and replacement part sales data, and other sources which drove AHM to issue Technical Service Bulletins acknowledging this defect. (Compl. ¶23.) Plaintiff also alleges sales representatives made several representations about the subject vehicle but, but did not disclose to Plaintiff any information about the Honda Sensing Defect. (Comp. ¶87.) Plaintiff alleges AHM intended to deceive Plaintiff by concealing the known issues with the Honda Sensing Defect, in an effort to sell the vehicle. (Compl. 117.)

 

It is true “[a]lthough, typically, a duty to disclose arises when a defendant owes a fiduciary duty to a plaintiff [citation], a duty to disclose may also arise when a defendant possesses or exerts control over material facts not readily available to the plaintiff. (See, e.g., Magpali v. Farmers Group, Inc. (1996) 48 Cal.App.4th 471, 482, 55 Cal.Rptr.2d 225 [“ ‘[t]he duty to disclose may arise without any confidential relationship where the defendant alone has knowledge of material facts which are not accessible to the plaintiff’ ”].)” (Jones v. ConocoPhillips Co. (2011) 198 Cal.App.4th 1187, 1199.) Plaintiff has adequately alleged that AHM possessed exclusive control over material facts not known to the general public about the Honda Sensing Defect and so had a duty to disclose this information to consumers.  Accordingly, Plaintiff’s allegations are sufficient to establish AHM’s knowledge of any alleged defect in the subject vehicle. 

 

Similarly, Plaintiff’s allegations are sufficient to establish AHM intentionally concealed or suppressed the material fact from Plaintiff. Plaintiff alleges AHM actively concealed the existence and nature of the Honda Sensing Defect from Plaintiff. Plaintiff claims AHM drafted, produced, and distributed marketing materials to the public containing factual representations about the Subject Vehicle and Plaintiff relied on the statements made during the sales process by AHM’s agents and within the marketing materials written by AHM.  Less particularity is required for allegations of fraudulent concealment.  Plaintiff’s allegations that AHM concealed information relating to the defect in all of its printed materials and in the oral representations made by sales persons and agents, is sufficient to allege active suppression of a material fact.  

 

Defendant AHM further argues even if Plaintiff claims to have relied on representations, misstatements, or omissions by AHM’s “network of dealers,” such conduct is not attributable to AHM or actionable against AHM. In support of this contention, Defendant AHM cites to several federal cases. Regardless, each do not suggest a bright line rule that “automobile dealerships cannot be the agents of manufacturers.” (Zeno v. Ford Motor Co., Inc. (W.D. Pa. 2007) 480 F.Supp.2d 825, 846.)

 

Next, Defendant AHM argues Plaintiff has failed to allege a duty to disclose. Defendant AHM contends any claim that a duty enumerated above arose from AHM's marketing brochures and general advertising to potential consumers fails as a transaction giving rise to a duty to disclose must necessarily arise from direct dealings between the plaintiff and the defendant.

 

In opposition, Plaintiff argues Defendant had a duty to disclose to alleged defect to Plaintiff prior to the Subject Vehicle’s purchase based on Defendant’s exclusive knowledge and a direct transaction between Plaintiff and Defendant per the recent holding of Dhital v. Nissan North America, Inc. (Dhital v. Nissan North America, Inc. (2022) 84 Cal.App.5th 828.)

 

As Plaintiff has sufficiently alleged AHM’s exclusive knowledge and active concealment of the defect with requisite factual specificity, Plaintiff has sufficiently alleged that AHM had a duty to disclose.

 

Defendant AHM makes a final argument that the damages claimed are purely economic and that the fraudulent concealment claim is barred by the economic loss rule.  “Simply stated, the economic loss rule provides: “‘“[W]here a purchaser's expectations in a sale are frustrated because the product he bought is not working properly, his remedy is said to be in contract alone, for he has suffered only ‘economic’ losses.’” This doctrine hinges on a distinction drawn between transactions involving the sale of goods for commercial purposes where economic expectations are protected by commercial and contract law, and those involving the sale of defective products to individual consumers who are injured in a manner which has traditionally been remedied by resort to the law of torts.” (Neibarger v. Universal Cooperatives, Inc. (1992) 439 Mich. 512, 486 N.W.2d 612, 615, fns. omitted.) The economic loss rule requires a purchaser to recover in contract for purely economic loss due to disappointed expectations, unless he can demonstrate harm above and beyond a broken contractual promise.  (Redarowicz v. Ohlendorf (1982) 92 Ill.2d 171, 65 Ill.Dec. 411, 441 N.E.2d 324, 327.) Quite simply, the economic loss rule ‘prevent[s] the law of contract and the law of tort from dissolving one into the other.’ (Rich Products Corp. v. Kemutec, Inc. (E.D.Wis.1999) 66 F.Supp.2d 937, 969.)”   (Robinson Helicopter Co., Inc. v. Dana Corp. (2004) 34 Cal.4th 979).  The Robinson Helicopter case carved out a narrow exception to that rule, where defendant makes affirmative misrepresentations on which a plaintiff relies, leading to a claim for fraud. 

 

Defendant argues this exception does not apply to a case of fraudulent concealment, as alleged here.  Plaintiff relies on Dhital, supra, which extended the ruling in Robinson Helicopters to fraudulent concealment claims.  Although Dhital is currently on review and has no precedential value, the court finds its analysis of Robinson Helicopters persuasive.  Dhital pointed out that the tort claims considered by the Supreme Court in Robinson Helicopters were premised on a duty that is either “completely independent of the contract or arises from conduct which is both intentional and intended to harm.’” (Id. at p. 990.)  Because “that independence is present in the case of fraudulent inducement (whether it is achieved by intentional concealment or by intentional affirmative misrepresentations), because a defendant's conduct in fraudulently inducing someone to enter a contract is separate from the defendant's later breach of the contract or warranty provisions that were agreed to,” the economic loss rule should not apply.  Here, plaintiffs’ fraudulent inducement claim alleges presale conduct by AHM (concealment) that is distinct from AHM’s's alleged subsequent conduct in breaching its warranty obligations, making the economic loss rule inapplicable. 

 

Motion to Strike

 

Defendant AHM moves to strike Plaintiff’s prayer for punitive damages on the grounds: (1) Plaintiff fails to plead with the requisite specificity facts showing AHM engaged in conduct rising to the level of malice, oppression, fraud, and therefore fails to allege sufficient facts to state a claim for punitive damages; and (2) Plaintiff fails to allege AHM's officers, directors, or managing agents engaged in or otherwise ratified the conduct Plaintiff contends is wrongful.

The court agrees that plaintiff has failed to plead punitive damages with the requisite specificity.  The motion to strike is granted with leave to amend.