Judge: William A. Crowfoot, Case: 21STCV46786, Date: 2022-12-21 Tentative Ruling
Case Number: 21STCV46786 Hearing Date: December 21, 2022 Dept: 27
SUPERIOR COURT OF THE STATE OF
CALIFORNIA
FOR THE COUNTY OF LOS ANGELES - CENTRAL
DISTRICT
I. INTRODUCTION
On December
23, 2021, plaintiff Russell Patten, individually and as the
successor-in-interest to and administrator of the Estate of Daniel Patten II
(“Decedent”), along with plaintiff Jennifer Patten (collectively,
“Plaintiffs”), filed this action against defendants City of Carson (“City”),
County of Los Angeles (“County”) (also erroneously sued as “Los Angeles County
Sheriff’s Department”), as well as other governmental entities, including
demurring defendant the People of the State of California, acting by and
through the California Department of Transportation (“Defendant”) (erroneously
sued as “State of California; California Department of Transportation”), and
the California Highway Patrol. The
action arises from illegal street racing that occurred on December 25, 2020, on
East 230th Street in the City of Carson.
Plaintiffs assert causes of action for general negligence and dangerous
condition of public property against the governmental entities.
On
August 8, 2022, Plaintiffs filed the operative First Amended Complaint (“FAC”). On November 18, 2022, Defendant filed this
demurrer to the Third Cause of Action of the FAC for “Vicarious Liability for
Act or Omissions of Public Employees.”
Defendant argues that the cause of action is uncertain and fails to
state sufficient facts to constitute a cause of action, and that the Court has
no jurisdiction over this cause of action.
On November
21, 2022, County and the Los Angeles County Sheriff’s Department filed a notice
joining in the demurrer and request a joint ruling in the context of a motion
for judgment on the pleadings because they have already filed an answer. Plaintiffs’ objected to this notice of
joinder on December 8, 2022, on the grounds that there is no basis for bringing
a motion for judgment on the pleadings and it was untimely filed.
II. LEGAL
STANDARDS
A demurrer tests the legal sufficiency
of the pleadings and will be sustained only where the pleading is defective on
its face. (City of Atascadero v. Merrill Lynch, Pierce, Fenner &
Smith, Inc. (1998) 68 Cal.App.4th 445, 459.) “We treat the demurrer as admitting all
material facts properly pleaded but not contentions, deductions or conclusions
of fact or law. We accept the factual
allegations of the complaint as true and also consider matters which may be
judicially noticed. [Citation.]” (Mitchell v. California Department of
Public Health (2016) 1 Cal.App.5th 1000, 1007; Del E. Webb Corp. v.
Structural Materials Co. (1981) 123 Cal.App.3d 593, 604 [“the facts alleged
in the pleading are deemed to be true, however improbable they may be”].) Allegations are to be liberally construed. (Code Civ. Proc., § 452.) A demurrer may be brought if insufficient
facts are stated to support the cause of action asserted. (Code Civ. Proc., § 430.10, subd. (e).)
Leave to amend must be allowed where
there is a reasonable possibility of successful amendment. (Goodman v. Kennedy (1976) 18 Cal.3d
335, 348.) The burden is on the
complainant to show the Court that a pleading can be amended successfully. (Ibid.)
III. DISCUSSION
Before filing a demurrer, the demurring
party shall meet and confer with the party who has filed the pleading and shall
file a declaration detailing their meet and confer efforts. (Code Civ. Proc., § 430.41, subd. (a).)
Defense
counsel, Manal H. Pelch, declares that the parties met and conferred on
September 28, 2022, September 29, 2022, and November 10, 2022. The meet and confer requirement is satisfied.
Defendant argues that Plaintiffs fail
to state any statutory basis of liability because Plaintiffs only cite to Civil
Code section 846(d)(1), which does not create a duty of care for a public
entity, but only protects landlords by limiting the duty of care owed by a
private property owner to persons using their property for recreational
purposes. (Demurrer, 5:18-6:10; FAC, ¶
32.)
In opposition, Plaintiffs argue that
they have sufficiently stated a statutory basis for vicarious liability by alleging
the alleged acts and omissions by Defendant’s employees. (See FAC, ¶¶ 31-2.)
The Court agrees with Defendant because
Plaintiffs fail to specifically identify the statutory basis for Defendant’s
alleged liability. A demurrer may be
sustained where the plaintiff fails to allege a statutory basis for liability
against a public entity. (Tilton v. Reclamation Dist. No. 800
(2006) 142 Cal.App.4th 848, 863-864 [affirming trial court’s sustaining a
demurrer without leave to amend as to four tort causes of action where
plaintiff failed to allege statutory basis—i.e., mandatory duty under
Government Code section 815.6—for liability against public entity].)
Additionally, even if Plaintiffs cited
to Government Code section 815.2, they would still fail to state a cause of
action. On December 7, 2022, the Court sustained
co-defendant California Highway Patrol’s demurrer to the same third cause of
action for “vicarious liability” on the grounds that there was no duty to
protect absent a special relationship.
Accordingly, Defendant’s demurrer to
the Third Cause of Action is SUSTAINED without leave to amend.
County’s joinder is not untimely
because it was served on November 21, 2022 before the deadline of November 23,
2022. Also, the failure to meet and
confer before filing a motion for judgment on the pleadings is not a basis for
denying the motion. (Code CIv. Proc., §
439, subd. (a)(4).) However, County
offers no authority for the Court to rule on a demurrer and simultaneously
construe that ruling as one for a motion for judgment on the pleadings. To the extent that County “request[s] a
ruling in the context of a motion for judgment on the pleadings”, the request
is DENIED.
IV. CONCLUSION
Defendant’s demurrer to Plaintiffs’
Third Cause of Action is SUSTAINED without leave to amend. County’s request is DENIED.
Moving party to give notice.
Parties who intend to submit on this
tentative must send an email to the Court at SSCDEPT27@lacourt.org indicating
intention to submit on the tentative as directed by the instructions provided
on the court website at www.lacourt.org.
Please be advised that if you submit on the tentative and elect not to
appear at the hearing, the opposing party may nevertheless appear at the
hearing and argue the matter. Unless you
receive a submission from all other parties in the matter, you should assume
that others might appear at the hearing to argue. If the Court does not receive emails from the
parties indicating submission on this tentative ruling and there are no
appearances at the hearing, the Court may, at its discretion, adopt the
tentative as the final order or place the motion off calendar.