Judge: Wesley L. Hsu, Case: 22PSCV00472, Date: 2023-03-28 Tentative Ruling
Case Number: 22PSCV00472 Hearing Date: March 28, 2023 Dept: L
Defendant Micron Environmental Labs, Inc.’s Motion to
Strike Punitive Damages from Second Amended Complaint is GRANTED.
Background    
Legal Standard
Pursuant to Code of Civil Procedure section 436, “the court may, upon a motion
made pursuant to Section 435, or at any time in its discretion, and upon terms
it deems proper: (a) Strike out any irrelevant, false, or improper matter
inserted in any pleading. (b) Strike out 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.” The grounds for a motion to strike must “appear on the
face of the challenged pleading or from any matter of which the court is
required to take judicial notice.” (Code Civ. Proc., § 437.)
Discussion 
Defendant moves the court for an order striking out all
references to exemplary/punitive damages at 17:4-7, 21:4-7, 25:7-9, 28:20-24,
32:4-7, 35:19-21, 38:25-28, 42:22-25, and Paragraph 8 of the Prayer for Relief
at 46:14 of Plaintiff’s SAC.
Punitive damages may be awarded upon clear and convincing evidence that a
defendant has been guilty of oppression, fraud, or malice. (Civ. Code § 3294,
subd. (a).) 
“Malice” is defined as “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.” (Civ. Code § 3294, subd. (c)(1).) 
“Oppression” is defined as “despicable conduct that subjects a person to
cruel and unjust hardship in conscious disregard of that person’s rights.”
(Civ. Code § 3294, subd. (c)(2).) “Fraud” is defined as “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.” (Civ. Code §
3294, subd. (c)(3).)
Further, “[a]n employer shall not be liable for damages pursuant to
subdivision (a), based upon acts of an employee of the employer, unless the
employer had advance knowledge of the unfitness of the employee and employed
him or her with a conscious disregard of the rights or safety of others or
authorized or ratified the wrongful conduct for which the damages are awarded
or was personally guilty of oppression, fraud, or malice. With respect to a
corporate employer, the advance knowledge and conscious disregard,
authorization, ratification or act of oppression, fraud, or malice must be on
the part of an officer, director, or managing agent of the corporation.” (Civ. Code § 3294, subd. (b).) 
A “conclusory characterization of defendant’s conduct as intentional,
willful and fraudulent is a patently insufficient statement of ‘oppression,
fraud, or malice. . .’” (Brousseau v.
Jarrett (1977) 73 Cal.App.3d 864, 872.) “The mere allegation an intentional
tort was committed is not sufficient to warrant an award of punitive damages.
Not only must there be circumstances of oppression, fraud, or malice, but facts
must be alleged in the pleading to support such a claim.” (Grieves v. Superior Court (1984) 157 Cal.App.3d 159, 166.) 
Here, Plaintiff has not pled facts supporting oppressive,
fraudulent, or malicious conduct. Plaintiff has alleged that she started
working at Defendant on January 10, 2022, that she disclosed to Nora Gamez
(“Gamez”), that she was pregnant at the end of her first shift, that she
requested and received approval for time off for doctor’s appointments,
pregnancy-related illness or emergencies, that Gamez became “tired of
[Plaintiff] taking time off,” that Gamez fired her “purely because [she] missed
work and would likely miss work in the future,” and that she was fired on April
12, 2022. (SAC, ¶¶ 11, 15, 16, 24, 25 and 32). 
“[W]rongful termination, without more, will not sustain a
finding of malice or oppression.” (Scott v. Phoenix Schools, Inc. (2009)
175 Cal.App.4th 702, 717.)
The motion, then, is granted.