Judge: Virginia Keeny, Case: 24STCV34001, Date: 2025-06-02 Tentative Ruling

Case Number: 24STCV34001    Hearing Date: June 2, 2025    Dept: 45

RAYMOND TISCARENO vs WALLGREENS CO., et al.

 

defendant wallgreen’s demurrer with motion to strike

 

Date of Hearing:        June 2, 2025                                       Trial Date:       N/A

Department:              45                                                        Case No.:        24STCV34001

 

Moving Party:            Defendant Walgreen Co.

Responding Party:     Plaintiff Raymond Tiscareno  

Meet and Confer:      Yes. (Nikolenko Decl.)   

 

BACKGROUND

 

On December 24, 2024, Plaintiff Raymond Tiscareno filed a complaint against Defendant Wallgreens Co., Allied Universal Security Services Universal Protection Service, LLC, Zurich American Insurance Company, Watermark Security Group, Inc. and Indian Harbor Insurance Company for (1) Personal Injury (Cal. Civ. Code §§ 3281 et seq.); (2) Assault and Battery (Cal. Penal Code §§ 240 et seq.) (3) Negligent Hiring and Supervision (Cal. Civ. Code §§ 1714(a) et seq.) (4) False Imprisonment (Cal. Civ. Code §§ 1708.5 et seq.) and (5) Intentional Infliction of Emotional Distress. Plaintiff alleges after visiting a Walgreens, he was approached by one of the Defendant’s security guards and accused of theft. Plaintiff alleges the security guard immediately yanked the scooter out of his hands, pepper-sprayed him, and forcibly tackled him to the ground, and proceeded to beat him with a baton.

 

On April 8, 2025, Plaintiff dismissed Indian Harbor Insurance Company.

 

[Tentative] Ruling

 

Defendant Walgreen Co.’s Demurrer is  OVERRULED. Defendant’s Motion to Strike is DENIED.

 

discussion

 

Defendant Walgreen Co. demurs to the complaint on the grounds each cause of action asserted against Walgreen Co. fails to assert facts sufficient to state a cause of action.

 

Uncertainty

 

Defendant Walgreen Co. demurs to the complaint on the grounds each cause of action relies upon Plaintiff’s inconsistent allegations that the security guard employed by Co-Defendant Allied Universal is somehow also employed in the same capacity by Walgreen Co. and three other Co-Defendants. Specifically, Defendant Walgreen Co. argues the complaint is comprised of repeated blanket statements that Walgreen Co.’s officers, directors and/or managing agents authorized/ratified the security guard’s conduct yet fails to provide actual facts that Walgreen Co. is vicariously responsible for the conduct of a security guard employed by a separate entity.

 

In opposition, Plaintiff argues the complaint clearly alleges Plaintiff was assaulted by a Walgreens-affiliated security guard just outside the premises, that the guard was acting within the course and scope of employment, and that Walgreens is liable under theories of respondeat superior, ratification, and negligent hiring and supervision.

 

The court finds the allegations are not so uncertain to sustain a demurrer. As alleged, whether the security guard is employed by one or all defendants can be determined during discovery. A demurrer based on uncertainty only applies where the complaint is so bad that a defendant cannot reasonably respond—i.e., cannot reasonably determine what issues must be admitted or denied, or what counts or claims are directed against him or her.  (Khoury v. Maly’s of Calif., Inc. (1993) 14 Cal.App.4th 612, 616.) 

 

First Cause of Action – “Negligence”

 

Defendant Walgreen Co. demurs to the first cause of action on the grounds it is unclear what cause of action Plaintiff attempts to assert here. Defendant argues there is no single theory of liability stated. Rather, the complaint unclearly states that Plaintiff suffered injury from the “negligence and intentional actions” of Defendants and thus should be awarded damages.

 

In opposition, Plaintiff argues Defendant mischaracterizes the nature of Plaintiff’s allegations as the first cause of action is clearly grounded in common law negligence and respondeat superior liability, both well-established bases for recovery under California law.

 

The court finds Plaintiff has sufficiently alleged a claim for negligence. To plead a cause of action for negligence, one must allege (1) a legal duty owed to plaintiffs to use due care; (2) breach of duty; (3) causation; and (4) damage to plaintiff. (County of Santa Clara v. Atlantic Richfield Co. (2006) 137 Cal. App. 4th 292, 318.) An employer may be vicariously liable for an employee’s tort, even if it was malicious, willful, or criminal if the employee’s acts was an “outgrowth” of his employment, “inherent in the working environment,” “typical of or broadly incidental to” the employer’s business, or, in a general way, foreseeable from his duties.  (Yamaguchi v. Harnsmut (2003) 106 Cal. App. 4th 472, 482.) Plaintiff here alleges that the conduct was taken in the course and scope of the guard’s employment by Walgreens, and/or Walgreen’s ratification, authorization or advance knowledge of the security guard’s conduct. As for whether the security guard was acting within the scope of his employment, a jury could find the security guard who assaulted Plaintiff was acting within the scope of their employment even if it was outside the store. Ordinarily, the determination of whether an employee has acted within the scope of employment presents a question of fact; it becomes a question of law, however, when the facts are undisputed and no conflicting inferences are possible.  (Lisa M. v. Henry Mayo Newhall Memorial Hospital (1995) 12 Cal.4th 291, 299.) 

 

Accordingly, the demurrer to the first cause of action is OVERRULED. 

 

Second Cause of Action – Assault & Battery

 

Defendant Walgreen Co. demurs to the second cause of action on the grounds Plaintiff has asserted no factual basis for finding Walgreen Co. vicariously liable for this intentional conduct, even if the court interprets the security guard to be an employee of Walgreen Co. for purposes of this demurrer.

 

The elements of a cause of action for assault are: (1) the defendant acted with intent to cause harmful or offensive contact, or threatened to touch the plaintiff in a harmful or offensive manner; (2) the plaintiff reasonably believed he was about to be touched in a harmful or offensive manner or it reasonably appeared to the plaintiff that the defendant was about to carry out the threat; (3) the plaintiff did not consent to the defendant's conduct; (4) the plaintiff was harmed; and (5) the defendant's conduct was a substantial factor in causing the plaintiff's harm.  (Carlsen v. Koivumaki (2014) 227 Cal.App.4th 879, 890.) The elements of a cause of action for battery are: (1) the defendant touched the plaintiff, or caused the plaintiff to be touched, with the intent to harm or offend the plaintiff; (2) the plaintiff did not consent to the touching; (3) the plaintiff was harmed or offended by the defendant's conduct; and (4) a reasonable person in the plaintiff's position would have been offended by the touching.  (Carlsen, supra, 227 Cal.App.4th at p. 890.) 

 

Defendant argues the type of harm allegedly suffered here is not inherent, typical of, incidental to, or otherwise a generally foreseeable consequence of the employer’s business. Moreover, Plaintiff has provided no facts in support of his allegations that Walgreen Co. acted with malice, fraud, and oppression in conscious disregard of Plaintiff’s rights.

 

In opposition, Plaintiff argues Plaintiff clearly pleads that he was pepper-sprayed, tackled, and beaten with a baton by a uniformed security guard acting with apparent or actual authority on behalf of Walgreens. Plaintiff alleges that the security guard was employed to deter theft and protect store property—a role that inherently carries a risk of physical confrontation. It is entirely foreseeable that a guard assigned such duties might use excessive force, even if such force is unauthorized.

 

As noted above, the court finds that under liberal pleading standards, these allegations are sufficient to allege that the security guard who assaulted Plaintiff was acting within the scope of their employment with Walgreen such that vicarious liability is imputed onto Walgreen. The court notes Walgreen disputes that the security guard was even employed by Walgreen. However, as alleged, the security guard was employed by at least Allied United and Walgreens and the parties can continue discovery to determine otherwise.

 

Accordingly, the demurrer to the second cause of action is OVERRULED.

 

Third Cause of Action – Negligent Hiring and Supervision

 

Defendant Walgreen Co. demurs to the third cause of action on the grounds the complaint fails to assert any facts establishing that Plaintiff’s harm was reasonably foreseeable.

 

A cause of action for negligent hiring, supervision, or retention of an employee requires the following elements: (1) the employer hired employee; (2) the employee was/became unfit or incompetent to perform the work for which he was hired; (3) the employer knew or should have known the employee was/became unfit or incompetent and that this unfitness or incompetence created a particular risk to others; (4) the employee’s unfitness or incompetence harmed plaintiff; and (5) the employer’s negligence in hiring/supervising/ retaining the employee was a substantial factor in causing plaintiff’s harm.¿ (Federico v. Superior Court (1997) 59 Cal.App.4th 1207, 1213-1214.)¿ To establish a cause of action for negligent hiring, retention, or supervision, a plaintiff must show that the employer knew or should have known that hiring or retaining the employee created a particular risk or hazard and that particular harm occurs.¿ (See Z.V. v. County of Riverside (2015) 238 Cal.App.4th 889, 902; Doe, supra, 50 Cal.App.4th at 1054.)¿ Negligent hiring, retention, or supervision is a form of direct negligence.¿ (Ibid.)¿ 

 

The complaint alleges “Defendant’s failure to properly vet and supervise its security guard, who engaged in unwarranted use of force against PLAINTIFF, constitutes negligent hiring and supervision.” (Compl. ¶54.) The court agrees the allegations are insufficient.

 

Plaintiff argues the allegations are sufficient because Walgreen Co. and its Co-Defendants hired or retained the security guard, placed him in a role requiring close contact with customers, and failed to properly screen, train, or supervise him—despite the foreseeable risk of using excessive force in a retail security setting. The complaint also alleges that failed to use ordinary care in the screening and hiring of the guard and failed to supervise the guard after he was hired.   These factual allegations are sufficient to plead a cause of action for negligent hiring and supervision against this defendant. 

 

Accordingly, the demurrer to the third cause of action is OVERRULED. 

 

Fourth Cause of Action – False Imprisonment

 

Defendant Walgreen Co. demurs to the fourth cause of action on the grounds the complaint fails to assert facts sufficient to state a cause of action for false imprisonment, even directly as to the security guard, because there are no facts showing that Plaintiff was ever confined or detained for an appreciable length of time.

 

The elements for false imprisonment are (1) nonconsensual, intentional confinement of a person, (2) without lawful privilege, (3) for an appreciable period of time, however brief. (Easton v. Sutter Coast Hosp. (2000) 80 Cal.App.4th 485, 496; see CACI 1400.) 

 

Defendant argues even assuming a direct theory of liability could be established as to the unnamed security guard, Plaintiff does not assert facts in support of finding Walgreen Co. vicariously liable for such intentional conduct – even if the court interprets the security guard to be an employee of Walgreen Co. for purposes of this demurrer.

 

In opposition, Plaintiff argues they did not need be physically restrained to be falsely imprisoned as California courts have long held that false imprisonment may be established by physical restraint, threats of force, or other conduct that would cause a reasonable person to believe they are not free to leave.

 

The court finds the allegations sufficient for the purposes of a demurrer. At the demurrer stage, a court only need to determine whether the facts alleged are sufficient to state a claim. A jury could find a security guard in an attempt to stop a theft leading to assault or false imprisonment is incidental to the enterprise. Moreover, as noted by Plaintiff, the alleged detention need only be for an appreciable length of time, however short.

 

Accordingly, the demurrer to the fourth cause of action is OVERRULED

 

Fifth Cause of Action – Intentional Infliction of Emotional Distress

 

Defendant Walgreen Co. demurs to the fifth cause of action on the grounds Plaintiff provides no facts in support of finding vicarious liability as to Walgreen Co. for the security guard’s conduct.

 

The court has found Plaintiff’s allegations for scope of employment sufficient, as well as the allegations for each cause of action.  Accordingly, plaintiff has sufficiently alleged a claim for IIED as to Walgreens based on those allegations and the allegations that Walgreens ratified and authorized the guard’s conduct.   

 

Sixth Cause of Action – Destruction of Property

 

Defendant Walgreen Co. demurs to the sixth cause of action on the grounds no facts exist in support of finding vicarious liability as to Walgreen Co. for the security guard’s conduct.

 

For reasons stated above, the sixth cause of action is OVERRULED.

 

Motion to Strike

 

Defendants moves to strike portions to the complaint on the grounds Plaintiff has pled no facts to support oppression, fraud or malice on the part of Walgreen Co., and thus is not entitled to seek punitive damages.

 

The court finds the allegations sufficient to show malice, oppression or fraud based on the allegations that Walgreens’ managing agents, directors or officers authorized or ratified this conduct. 

 

The motion to strike is DENIED.





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